Justia Government & Administrative Law Opinion Summaries

A former Michigan Department of Corrections prisoner with asthma and an alleged allergy to dogs experienced allergic reactions while incarcerated at multiple facilities that housed dogs for training purposes. He reported symptoms such as asthma attacks and respiratory infections to prison officials, who provided prescribed treatments but did not confirm a specific dog allergy. After pursuing the prison’s grievance process, he was moved within the facility but still encountered dogs during required programming. Subsequently, he requested an ADA accommodation to be housed away from dogs, but this was denied due to lack of medical documentation. He later filed suit, alleging violations of the Eighth Amendment, the ADA, the Rehabilitation Act, and state laws.The United States District Court for the Western District of Michigan granted summary judgment in favor of the defendants. The court found that prison officials were not deliberately indifferent to his medical needs under the Eighth Amendment, as they consulted medical staff who did not recommend a transfer based on his condition. For the ADA and Rehabilitation Act claims, the court determined that inadequate medical treatment was not actionable under those statutes and that the plaintiff had not demonstrated denial of prison services or programs due to his disability. The court also declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the grant of summary judgment, holding that the prison counselor was entitled to qualified immunity because no clearly established law required the transfer of prisoners with asthma to facilities without dog programs. The court also found that the plaintiff failed to provide sufficient medical documentation to support the necessity of the requested accommodation under the ADA and Rehabilitation Act and did not establish discriminatory animus. The district court’s refusal to exercise supplemental jurisdiction over state-law claims was also affirmed. View "Miles-El v. Michigan" on Justia Law

A patient at Coalinga State Hospital challenged a policy and regulation that permitted hospital staff to x-ray and open all incoming mail outside the presence of patients. He argued that this policy conflicted with certain provisions of the Welfare and Institutions Code and regulations, which he claimed guaranteed patients the right to receive unopened correspondence. The patient, who is civilly committed as a sexually violent predator (SVP), alleged his mail had been opened and contents withheld without his permission, and he sought a judicial declaration concerning his rights under state law.The Superior Court of Fresno County sustained a demurrer filed by the Department of State Hospitals Coalinga and its Hospital Police Chief. The court concluded that the statutory rights cited by the patient, specifically those in Welfare and Institutions Code section 5325, applied only to individuals committed under the Lanterman-Petris-Short (LPS) Act, not to SVPs. The court also found that the regulation authorizing inspection of mail for non-LPS patients did not conflict with the statute, as they applied to different populations. The patient's amended petition was dismissed without leave to amend.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the lower court’s judgment. The appellate court held that Welfare and Institutions Code section 5325 confers mail rights only to LPS patients and that sexually violent predators, as non-LPS patients, are governed by separate regulations under title 9, section 884, which specifically allows for the inspection of their mail. The court found no irreconcilable conflict between the statute and the regulation and concluded that the Department of State Hospitals has authority to adopt regulations necessary for institutional security. The judgment dismissing the patient’s amended petition was affirmed. View "Seeboth v. State Dept. of State Hospitals" on Justia Law

Federal agents executed a pre-dawn raid targeting a gang member in Atlanta, but mistakenly entered the plaintiffs’ residence, three houses away from the intended address and on a different street. The FBI SWAT team forcibly entered, detonated a flash-bang grenade, and detained the plaintiffs, including a minor, before realizing their error and departing. The raid’s leader, Agent Guerra, later attributed the mistake to his personal GPS device, which he discarded shortly after the incident. Plaintiffs disputed the adequacy of pre-raid preparations and alleged multiple torts and constitutional violations.The plaintiffs filed suit in the United States District Court for the Northern District of Georgia, asserting claims against the United States under the Federal Tort Claims Act (FTCA) for false arrest, assault and battery, trespass, emotional distress, and negligence, as well as a Bivens claim against Agent Guerra and others for Fourth Amendment violations. The district court granted summary judgment to the United States on most FTCA claims under the discretionary-function exception, and to Agent Guerra on the Bivens claim based on qualified immunity. After an intervening Eleventh Circuit decision, the district court granted judgment to the government on the remaining FTCA claims.On appeal, the United States Court of Appeals for the Eleventh Circuit was instructed by the Supreme Court (following Martin v. United States, 605 U.S. 395 (2025)) to re-examine whether the FTCA’s discretionary-function exception barred the plaintiffs’ claims. The Eleventh Circuit held that the discretionary-function exception shielded the United States from all FTCA claims arising from the raid and affirmed their dismissal. However, the court reversed the grant of qualified immunity to Agent Guerra, finding that, when viewing the evidence most favorably to the plaintiffs, his actions violated clearly established Fourth Amendment law. The case was remanded for further proceedings consistent with these holdings. View "Martin v. USA" on Justia Law

In August 2021, a city implemented a COVID-19 vaccination policy for its employees, requiring them to either receive the vaccine or request a medical or religious exemption. Employees granted an exemption were required to undergo weekly COVID-19 testing and wear masks in shared spaces. One employee, a forensic specialist, requested and received a religious exemption but objected to the testing and masking requirements, claiming they revealed his unvaccinated status and created a hostile work environment. He was placed on unpaid leave for refusing to comply but eventually agreed to the requirements and returned to work. He continued to challenge the policy until it was rescinded in March 2022.The employee filed suit in the United States District Court for the Central District of California, asserting federal and state claims against the city and several employees related to the testing and masking requirements. The district court found that the Public Readiness and Emergency Preparedness (PREP) Act applied but initially did not grant immunity to all individual defendants for each claim. Ultimately, the court dismissed the complaints, denied the employee’s motion for reconsideration, and entered judgment for the defendants.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that both the city and individual defendants were “covered persons” under the PREP Act, and that COVID-19 tests and masks constituted “covered countermeasures” authorized for emergency use. The court clarified that the causation requirement for PREP Act immunity is satisfied if the injury alleged arises from the administration or use of a covered countermeasure, regardless of the legal theory. Because the employee’s alleged harms were directly linked to the city’s COVID-19 safety policy, the court affirmed the district court’s dismissal and denial of reconsideration, holding that PREP Act immunity barred all claims. View "SCHMIDT V. CITY OF PASADENA" on Justia Law

A politically active resident of East Cleveland, Ohio, who had long used a sound truck to broadcast political messages, supported a challenger in a mayoral primary. After this involvement, city officials began enforcing rarely used parking and noise ordinances against him. The plaintiff was warned, cited, had his truck impounded, and was prosecuted for a noise violation. He alleged that these actions were motivated by his support for the challenger and criticism of the administration. The plaintiff, along with his company, brought claims under 42 U.S.C. § 1983 against the city, the mayor, the mayor’s chief of staff, and the police chief, asserting First Amendment retaliation and prior-restraint violations, as well as Fourth and Fourteenth Amendment claims.The United States District Court for the Northern District of Ohio resolved all claims in favor of the defendants. Some claims—including First Amendment retaliation claims against the mayor and chief of staff—were dismissed at the pleading stage, while others were resolved at summary judgment. The court found that the ordinances were facially valid and that the plaintiff had either failed to establish the required elements for his claims or had forfeited certain arguments on appeal.On appeal, the United States Court of Appeals for the Sixth Circuit revived certain First Amendment retaliation claims. It held that the district court erred in applying the probable cause requirement to the retaliation claims against the mayor and chief of staff, reversing their dismissal. The court affirmed summary judgment for the police chief on qualified immunity grounds, finding no clearly established law that would make him liable as a conduit for another’s retaliatory motive. As to the city, the court vacated summary judgment on retaliation, remanding for further proceedings on whether municipal policy directly caused a constitutional violation. The court affirmed the district court on all other claims, including the prior-restraint and Fourth Amendment seizure claims, and noted that the plaintiff had forfeited his selective enforcement arguments on appeal. View "Fambrough v. City of E. Cleveland" on Justia Law

Three transgender individuals sought to amend the sex designations on their Oklahoma birth certificates to align with their gender identities. They obtained state court orders directing these changes, but when presented to the Oklahoma State Department of Health, the applications were denied. The denial was based on an executive order issued by the Governor, which instructed the agency to cease amending birth certificates in ways not explicitly permitted by Oklahoma law.Plaintiffs filed suit in the United States District Court for the Northern District of Oklahoma, raising equal protection and due process claims against state officials. The District Court granted the defendants’ motion to dismiss, and plaintiffs appealed to the United States Court of Appeals for the Tenth Circuit. The Tenth Circuit affirmed dismissal of the due process claim but reversed on the equal protection claim. Defendants sought certiorari in the United States Supreme Court, which issued a Grant, Vacate, Remand order directing the Tenth Circuit to reconsider in light of United States v. Skrmetti, 605 U.S. 495 (2025). Subsequently, the Tenth Circuit certified three questions of Oklahoma law to the Supreme Court of Oklahoma.The Supreme Court of the State of Oklahoma held that Oklahoma Statute 63 O.S. § 1-321, as amended by § 1-321(H), prohibits changes to the sex designation on an Oklahoma birth certificate. The court further determined that neither current nor prior versions of the statute have ever permitted such changes, whether based on gender identity or otherwise. The answers to the certified questions were: 1) yes, the statute prohibits changes; 2) no, it has never permitted such changes; and 3) no, it does not now nor has ever permitted changes based on gender identity. View "FOWLER v. STITT" on Justia Law

The City of Los Angeles received millions in federal housing grants over a period of years, certifying compliance with federal housing accessibility laws as a condition of those funds. Mei Ling and the Fair Housing Council of the San Fernando Valley (FHC) brought a qui tam action under the False Claims Act (FCA), alleging that the City had falsely represented its compliance with accessibility requirements. The United States later intervened in the case. Separately, the Department of Housing and Urban Development (HUD) investigated the City for noncompliance and, after its own findings, entered into a Voluntary Compliance Agreement (VCA) with the City. Under the VCA, the City agreed to spend at least $200 million over ten years to remediate or build accessible housing, but the VCA explicitly excluded the FCA claims at issue in the litigation.The United States District Court for the Central District of California presided over years of discovery and litigation. Eventually, the United States, FHC, and the City agreed to settle the FCA claims for $38,266,989. The district court approved the settlement as fair, adequate, and reasonable, and dismissed all claims against the City, with relators entitled to a statutory share of the settlement proceeds. Mei Ling appealed, arguing that the VCA constituted an “alternate remedy” under the FCA, which would entitle her to a share of the VCA’s value.The United States Court of Appeals for the Ninth Circuit held that the VCA was not an alternate remedy within the meaning of 31 U.S.C. § 3730(c)(5) because it did not take the place of the FCA suit or settlement. The VCA addressed the City’s civil rights violations, not the alleged fraud underlying the FCA action, and expressly carved out the FCA claims. The Ninth Circuit affirmed the district court’s approval of the FCA settlement. View "LING V. CITY OF LOS ANGELES" on Justia Law

A class of noncitizens with final removal orders challenged new Department of Homeland Security (DHS) policies issued in March and July 2025, which authorized their removal to “third countries”—countries neither designated in their removal orders nor identified in writing during prior proceedings. The plaintiffs alleged that DHS’s policy failed to provide effective notice or a meaningful opportunity to contest removal to these third countries based on reasonable fear of persecution or torture. The policies also relied on diplomatic assurances from receiving countries, sometimes removing individuals without further protective procedures.The United States District Court for the District of Massachusetts issued a temporary restraining order, granted class certification, and later a preliminary injunction requiring DHS to provide written notice and an opportunity for class members to assert fear-based claims before any third-country removal. After DHS appealed, the U.S. Supreme Court granted a stay pending appellate review. On remand, the district court dissolved the preliminary injunction and issued a final judgment, concluding that DHS’s guidance violated statutory requirements for sequencing removal destinations, and failed to provide notice and hearing for fear-based claims, including those under the Convention Against Torture (CAT). The court ordered declaratory relief and vacated the guidance as unlawful under the Administrative Procedure Act (APA).On appeal, the United States Court of Appeals for the First Circuit held that the plaintiffs lacked Article III standing on the “sequencing” claim and vacated the related declarations. However, the court affirmed the district court’s judgment that DHS must provide effective notice and a meaningful opportunity to contest removal to a third country based on fear-based claims, and upheld the vacatur of DHS guidance as unlawful under the APA. The court rejected DHS’s jurisdictional and remedy arguments, clarifying that declaratory and vacatur relief were permissible and not barred by statute. View "D.V.D. v. Department of Homeland Security" on Justia Law

Several companies sought to develop a property in Centerville, Ohio, proposing a gas station, convenience store, and drive-through restaurant. The Centerville Planning Commission approved their major site plan, but some community members, including Bethany Village and Epiphany Evangelical Lutheran Church, opposed the project and appealed to the Centerville City Council. The city council reversed the planning commission’s approval, blocking the development.After the city council’s reversal, the companies filed two actions in the Montgomery County Court of Common Pleas. The first was an administrative appeal under Ohio Revised Code Chapter 2506, challenging the council’s decision. The second was a separate lawsuit seeking damages and declaratory relief under 42 U.S.C. § 1983, naming the city, city council, and other interested parties as defendants. The city and council removed the § 1983 action to the United States District Court for the Southern District of Ohio. The administrative appeal succeeded, with the common pleas court finding the city council’s reversal was improper.Following the administrative appeal’s outcome, the federal court questioned whether the doctrine of res judicata barred the § 1983 action, since it arose from the same transaction as the administrative appeal. The federal court noted conflicting precedents and certified the question to the Supreme Court of Ohio.The Supreme Court of Ohio answered the certified question in the negative, holding that res judicata does not bar a party from bringing claims for damages or declaratory relief in a subsequent action when such claims could not have been brought within an R.C. Chapter 2506 administrative appeal. The court clarified that administrative appeals are limited to judicial review and cannot address damages or declaratory relief, so claim preclusion does not apply to those subsequent claims. View "Sheetz, Inc. v. Centerville" on Justia Law

Twin brothers, both Black international students, were enrolled as doctoral candidates at the University of Mississippi’s Department of Pharmacy Administration. One brother, Bennard, disagreed with changes to his faculty mentorship arrangement, objected to mandatory in-person meetings, and declined to complete a required program assessment called the Abilities Transcript. After being repeatedly warned and given extensions, he was placed on provisional status for failing to complete the requirement, which also caused the loss of his graduate assistantship. Bennard and his brother each filed lawsuits against the University and several faculty members, alleging constitutional, statutory, and contract violations related to academic sanctions and alleged discriminatory treatment.The United States District Court for the Northern District of Mississippi consolidated the brothers’ cases. It dismissed Bennard’s claims against the University on sovereign-immunity grounds, dismissed his remaining federal claims under Rule 12(b)(6) for failure to state a claim, and declined to exercise supplemental jurisdiction over his individual-capacity state contract claims. Bennard appealed, while his brother’s appeal was dismissed for failure to prosecute.The United States Court of Appeals for the Fifth Circuit reviewed Bennard’s remaining claims. The court held that sovereign immunity barred claims against the University, claims against one defendant in her official capacity, and official-capacity state-law contract claims; those dismissals must be without prejudice. The court further found that Bennard failed to plausibly allege First or Fourteenth Amendment violations, and that the faculty defendants were entitled to qualified immunity on individual-capacity claims. The court affirmed the district court’s refusal to exercise supplemental jurisdiction over the remaining contract claims and upheld consolidation of the cases and dismissal of moot preliminary injunction motions. The judgment was affirmed as modified to clarify the proper form of dismissal for sovereign-immunity-barred claims. View "Eriakha v. University of MS" on Justia Law