Justia Government & Administrative Law Opinion Summaries

Several current and former employees of the City of Chicago, including police officers and an emergency management officer, challenged the City’s COVID-19 vaccination policy. The policy, issued in October 2021, required city employees to either be vaccinated against COVID-19 or undergo regular testing and report their status through an employee portal. Religious exemptions from vaccination were available and granted to these plaintiffs, but the plaintiffs objected to having to submit their vaccination status and test results in the portal, arguing that this reporting requirement violated their constitutional and statutory rights.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, raising claims under Title VII of the Civil Rights Act of 1964, the First and Fourteenth Amendments via 42 U.S.C. § 1983, and the Illinois Religious Freedom Restoration Act (IRFRA). The district court dismissed the Third Amended Complaint for failure to state a claim. It found the Title VII claims factually implausible and concluded that the plaintiffs did not allege a religious practice conflicting with the reporting requirements. The court also held that, since the plaintiffs were granted their requested exemptions from vaccination, they could not succeed on claims based on their refusal to comply with reporting requirements.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The Seventh Circuit held that the policy’s reporting requirements were neutral and generally applicable, subject only to rational-basis review, which the policy satisfied. The court determined that the reporting and disciplinary provisions were rationally related to the City’s legitimate interest in public health and workplace safety. The court affirmed the district court’s dismissal of all constitutional, statutory, and state-law claims, finding the plaintiffs’ arguments insufficient to state a plausible claim for relief. View "Kondilis v City of Chicago" on Justia Law

A licensed horse trainer was involved in a dispute with a state racing steward after the steward refused to reinstate an assistant trainer’s license. Following a heated phone conversation in which the trainer criticized the steward, the state agency regulating horse racing initiated a disciplinary action against the trainer, alleging conduct that could negatively reflect on the integrity of horse racing. A panel of stewards found a violation and issued a conditional fine. The trainer appealed for a de novo administrative hearing but later withdrew the appeal and instead filed a lawsuit in district court, claiming the agency’s actions were a retaliatory violation of his state constitutional rights under the New Mexico Civil Rights Act.The district court denied the agency’s motion for summary judgment, holding that judicial immunity was not available to the public body under the Civil Rights Act. On interlocutory appeal, the New Mexico Court of Appeals reversed, finding that the statutory language preserved judicial immunity as a defense and that the agency was entitled to quasi-judicial immunity based on its role and the nature of the proceedings, directing entry of summary judgment for the agency.The Supreme Court of the State of New Mexico reviewed whether judicial immunity is a defense available to a public body sued under the New Mexico Civil Rights Act. The Court held that judicial immunity does apply to public bodies in this context, reasoning that the doctrine’s policy goals—protecting independent decision-making and the integrity of judicial or quasi-judicial processes—apply to both individuals and government entities. However, the Court found the record insufficient to decide whether the agency’s conduct warranted immunity under this standard and remanded the matter to the district court for further proceedings consistent with its clarified framework. The Court affirmed in part and reversed in part the Court of Appeals’ decision. View "Bolen v. N.M. Racing Commission" on Justia Law

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

A high-speed police pursuit in Iowa ended with a motorcycle crash that left the rider, Augustin G. Mormann, paralyzed and ultimately led to his death after life support was withdrawn. The chase began when an Iowa State Trooper attempted to stop Mormann for speeding, but he fled, weaving through traffic and entering residential neighborhoods. The trooper disengaged due to safety concerns, but Manchester police officer James Wessels continued the pursuit at speeds exceeding 100 miles per hour. During the chase on a county road, Wessels’s police cruiser struck Mormann's motorcycle, leading to a crash that caused catastrophic injuries. Mormann was hospitalized, tested positive for methamphetamine, and died after choosing to discontinue life support. His family subsequently filed a civil suit against Wessels and the City of Manchester.In the Iowa District Court for Delaware County, the plaintiffs asserted claims including constitutional violations and, ultimately, common law assault and battery. The district court dismissed the constitutional claims after a change in Iowa law but allowed the assault and battery claims to proceed to trial. The jury found Wessels liable for both torts, awarding $4.25 million in compensatory damages and $10,000 in punitive damages. The court denied post-trial motions for judgment notwithstanding the verdict and for a new trial.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. View "Mormann v. City of Manchester, Iowa" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

A Concord police officer discovered her firearm missing from the station’s lockers in 2013. Investigation revealed that another officer, the plaintiff, had mistakenly taken the firearm while transporting a prisoner to a hospital. The plaintiff gave inconsistent accounts about when she realized the mistake, telling supervisors she noticed it at the station, while her partner reported she only realized it at the hospital. An internal affairs investigation found the plaintiff’s statements lacked credibility and concluded she had lied to colleagues and supervisors about the incident. The police chief sustained these findings, terminated her employment, and submitted her name for inclusion on the Exculpatory Evidence Schedule (EES), formerly known as the “Laurie List.”The plaintiff appealed her termination to the City of Concord’s Personnel Appeals Board, which upheld the decision, finding her lacked credibility. She then filed a complaint in the Superior Court alleging gender discrimination and wrongful termination, which was settled. The settlement required the City to remove documents related to the incident from her personnel file and maintain them in a separate investigative file, and to report her departure as a negotiated resignation.Years later, the plaintiff sued the City and the New Hampshire Department of Justice in Superior Court, seeking removal of her name from the EES under RSA 105:13-d. She argued the alleged misconduct was immaterial, the records were no longer in her personnel file, and her inclusion on the EES was unwarranted given the passage of time. The Superior Court granted summary judgment for the defendants.The Supreme Court of New Hampshire affirmed, holding that RSA 105:13-d governs EES inclusion and applies to “personnel information,” not just personnel files. The court found the plaintiff’s untruthfulness constituted potentially exculpatory evidence and that it was reasonably foreseeable her misconduct could be admissible to impeach her credibility if she were called as a witness in a future case. View "Doe v. Concord Police Department" on Justia Law

While incarcerated at High Desert State Prison in Clark County, Brian Caperonis was killed by other inmates. His father, William Joseph Caperonis, acting individually and as the special administrator of Brian’s estate, filed a civil complaint against the Nevada Department of Corrections (NDOC) and several of its employees. The claims included civil rights violations under 42 U.S.C. § 1983, wrongful death, and various negligence claims related to Brian’s death.NDOC moved to dismiss the state law negligence claims, arguing that the estate had failed to exhaust administrative remedies as required by NRS 41.0322 and NRS 209.243. NDOC asserted that, as the estate stands in the shoes of the decedent, it was required to file an administrative claim before pursuing litigation. William opposed, contending that the exhaustion requirement applied only to living inmates and not to the estates of deceased prisoners. The Eighth Judicial District Court denied NDOC’s motion to dismiss, finding that the plain language of the statutes and the relevant administrative regulations did not extend the exhaustion requirement to estates of deceased inmates.The Supreme Court of Nevada reviewed NDOC’s petition for a writ of mandamus. The court held that the administrative exhaustion requirements in NRS 41.0322 and NRS 209.243 do not apply to the estate of a deceased prisoner. The court reasoned that the statutory language is limited to “a person who is or was” in NDOC custody and does not contemplate survival claims by estates. The court also found that the administrative regulations provide no mechanism for an estate to pursue such remedies. Accordingly, the Supreme Court of Nevada denied NDOC’s writ petition, affirming the district court’s decision. View "Department of Corrections v. District Court" on Justia Law

A resident of University Heights, Ohio, who practices Orthodox Judaism, sought to use his home for group prayer sessions due to religious obligations and restrictions on travel during the Sabbath. After inviting neighbors to participate in these gatherings, a neighbor complained to city officials, prompting the city’s law director to send a cease-and-desist letter, warning that using the home as a place of religious assembly violated local zoning laws. The resident then applied for a special use permit to operate a house of worship but withdrew his application before the city’s Planning Commission could reach a decision, stating he did not wish to operate a house of worship as defined by the ordinance. Despite withdrawing, he later filed a federal lawsuit against the city and several officials, alleging violations of federal and state law, including constitutional and statutory claims.The United States District Court for the Northern District of Ohio granted summary judgment for the city and its officials. The court found that the plaintiff’s claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the First and Fourteenth Amendments, and the Ohio Constitution were unripe because there was no final decision by the relevant local authorities regarding the application of the zoning ordinance to his property. The court also rejected his Fourth Amendment and Freedom of Access to Clinic Entrances Act (FACE Act) claims on the merits and declined supplemental jurisdiction over a state public records claim.The United States Court of Appeals for the Sixth Circuit affirmed. The court held that most of the plaintiff’s claims were unripe because he withdrew his application before any final decision was made by the city’s zoning authorities, and thus there was no concrete dispute for federal review. The court also held that his facial challenges to the ordinance were forfeited and, in any event, failed as a matter of law. The court further concluded that the Fourth Amendment and FACE Act claims failed on the merits and found no abuse of discretion in declining supplemental jurisdiction over the state law claim. View "Daniel Grand v. City of University Heights, Ohio" on Justia Law

An armed fugitive fleeing law enforcement entered a print shop owned by the plaintiff, forcibly removed him, and barricaded himself inside. After a thirteen-hour standoff, Los Angeles Police Department SWAT officers used dozens of tear gas canisters to subdue the fugitive, causing significant damage to the shop and its contents. The parties agreed that the officers’ actions were authorized, reasonable, and lawful. The plaintiff alleged that the damages, which exceeded $60,000, were caused exclusively by the police.The plaintiff initially sought compensation from the United States Marshals Service, which denied the claim and referred him to the City of Los Angeles. After the City did not respond to his claims or his attorney’s letter, the plaintiff filed a federal lawsuit under 42 U.S.C. § 1983, asserting a violation of the Fifth Amendment’s Takings Clause. The City moved for judgment on the pleadings, arguing that the Takings Clause does not require compensation for property destroyed by police acting reasonably in an emergency. The United States District Court for the Central District of California denied the City’s initial motion but later granted summary judgment for the City, finding that the destruction was a valid exercise of police power and not a compensable taking.The United States Court of Appeals for the Ninth Circuit reviewed the case de novo. The court held that the government’s destruction of private property, when necessary and reasonable for public safety, is exempt from the Takings Clause. The court relied on historical understanding and longstanding precedent, concluding that such actions fall outside the scope of the Takings Clause. Accordingly, the Ninth Circuit affirmed the district court’s judgment, holding that the plaintiff failed to state a claim for a compensable taking under the Fifth Amendment. View "PENA V. CITY OF LOS ANGELES" on Justia Law