Justia Government & Administrative Law Opinion Summaries

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

Rocky Freeman was involved in a Brooklyn drug ring and was hired to kill a rival dealer, Freddie Gonzalez, in 1993. He was later arrested and charged in the United States District Court for the Eastern District of New York with drug conspiracy, the Gonzalez murder, and the unrelated murder of Augustin Sosa. At trial, Freeman was convicted of the drug and Gonzalez murder counts but acquitted of the Sosa murder. However, his presentence report (PSR) incorrectly stated that he had committed both murders. Although a judge ordered the error corrected, the PSR was not amended, and the inaccurate report was transmitted to the Bureau of Prisons (BOP). Freeman subsequently endured heightened security conditions in prison, including solitary confinement and severe restrictions, which he later attributed to the erroneous PSR.Freeman discovered the error in 2015 and pursued administrative remedies, including filing an SF-95 form alleging a Federal Tort Claims Act (FTCA) violation. He then filed a civil complaint in the United States District Court for the Middle District of Pennsylvania against the BOP, the U.S. Probation Office (USPO), his unit manager, and probation officers, alleging FTCA and Bivens claims. The District Court dismissed his FTCA claim for lack of jurisdiction and on the merits, and dismissed his Bivens claim for failure to serve the probation officers. Freeman appealed.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that the District Court erred in dismissing Freeman’s FTCA claim for lack of jurisdiction, finding that he had properly presented his claim to the appropriate agency. The court also held that the District Court improperly applied the Prison Litigation Reform Act’s physical injury requirement to the FTCA presentment phase. The Third Circuit reversed the dismissal of the FTCA claim and remanded for further proceedings. However, the court affirmed the dismissal of Freeman’s Bivens claim, concluding that his claim was not cognizable under current Supreme Court precedent. View "Freeman v. Lincalis" on Justia Law

Residents and the municipality of Morovis, Puerto Rico, brought suit against the Puerto Rico Aqueduct and Sewer Authority (PRASA) and its officials, alleging that for years, Morovis has suffered from a severe water crisis, with many residents lacking water service on most days. The plaintiffs, all PRASA subscribers, claimed that despite repeated notifications and proposed solutions—including a report from the U.S. Army Corps of Engineers—PRASA failed to address the crisis. They alleged that sometimes the outages could be resolved by simply turning on pumps or generators, and that PRASA officials were aware of the situation but did little to provide alternative water sources or adjust billing. The plaintiffs also recounted incidents suggesting deliberate inaction or sabotage by PRASA employees.The United States District Court for the District of Puerto Rico dismissed the case in its entirety at the pleading stage, concluding that the plaintiffs failed to state a claim for a substantive due process violation under the Fourteenth Amendment. The court found that the alleged conduct did not rise to the level of “shocking the conscience,” and also held that the plaintiffs’ contracts with PRASA could not form the basis of a substantive due process claim. The court did not decide whether Puerto Rico law created a protected property interest in water service.On appeal, the United States Court of Appeals for the First Circuit held that the district court erred in dismissing the substantive due process claim. The First Circuit ruled that the plaintiffs plausibly alleged government conduct that could shock the conscience, particularly under a deliberate indifference standard, given the prolonged and severe deprivation of water. The court vacated the district court’s dismissal and remanded for further proceedings, leaving unresolved whether a protected property interest exists and whether qualified immunity applies. View "Maldonado-Gonzalez v. Puerto Rico Aqueduct & Sewer Authority" on Justia Law

A woman with a lifelong hearing impairment obtained a commercial driver’s license (CDL) in New Jersey after receiving a federal exemption from the standard hearing requirement. This exemption allowed her to drive commercial vehicles in interstate commerce but specifically prohibited her from operating passenger vehicles or school buses. Despite this, she was mistakenly issued state endorsements permitting her to drive such vehicles and worked as a campus shuttle bus driver for about eight months. When the New Jersey Motor Vehicle Commission (NJMVC) realized the error, it revoked her passenger and school bus endorsements without providing a pre-revocation hearing.Instead of seeking review in New Jersey Superior Court, the woman filed suit in the United States District Court for the District of New Jersey. She alleged violations of Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and New Jersey’s Law Against Discrimination, as well as a procedural due process claim under 42 U.S.C. § 1983. The District Court dismissed some claims and ultimately granted summary judgment to the defendants on all remaining claims, finding she was not “qualified” for the endorsements and had no property interest in them.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The court held that the plaintiff was not a “qualified individual with a disability” under the relevant statutes because she could not meet the essential eligibility requirement of passing the hearing test for the endorsements. The court also held that, even assuming a property interest in the endorsements, due process did not require a pre-revocation hearing given the state’s strong safety interests and the availability of post-deprivation remedies. The court affirmed summary judgment for the defendants on all claims. View "Parker v. New Jersey Motor Vehicle Commission" on Justia Law

A 70-year-old woman was the subject of a state petition for involuntary civil commitment, alleging she suffered from a severe mental disorder with manic and psychotic features. Over several months, she had multiple encounters with law enforcement and was charged with various offenses, including assault and disorderly conduct. The petition included a psychiatric evaluation and described significant behavioral changes affecting her safety and relationships. At the initial hearing, the woman was represented by counsel, who stated she did not want a trial and wished to be stabilized, and the court read her rights aloud.The Eighth Judicial District Court, Cascade County, presided over the hearing. The court relied on the representations of counsel and the woman’s brief affirmations to find that she knowingly and intentionally waived her procedural rights, including the right to contest the commitment. The court then ordered her commitment to the Montana State Hospital for up to 90 days, issuing findings that largely repeated the petition’s allegations. The order stated that the woman and her counsel agreed to waive her rights, but the court did not directly question her about the waiver or develop a record of her understanding.The Supreme Court of the State of Montana reviewed the case. It held that the district court erred by failing to make an adequate inquiry or develop a sufficient record to support a finding that the woman knowingly and intentionally waived her rights, as required by Montana law. The Supreme Court emphasized that merely informing a respondent of their rights or relying on general statements from counsel is insufficient. The order of commitment was reversed, reaffirming the necessity for strict compliance with statutory and due process requirements in involuntary commitment proceedings. View "In re P.G.J." on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

Two inmates in Virginia, each serving sentences for attempted aggravated murder, were initially informed by the Department of Corrections that they would be released in July 2022 due to a new state law expanding sentence credits for good behavior. This law, H.B. 5148, allowed certain inmates to earn more credits and thus reduce their incarceration time. However, after a change in the Attorney General’s office, the new Attorney General issued an advisory opinion stating that inmates convicted of inchoate offenses related to aggravated murder were not eligible for the enhanced credits. As a result, the Department reversed its earlier decision and kept the inmates incarcerated for an additional year, until the Supreme Court of Virginia later clarified that such inmates were indeed eligible for the credits and ordered their release.The inmates then filed a lawsuit in the United States District Court for the Eastern District of Virginia, seeking damages under 42 U.S.C. § 1983. They alleged that the Attorney General and the Director of Corrections violated their Eighth and Fourteenth Amendment rights by acting with deliberate indifference to their over-incarceration. The district court dismissed the complaint, finding that both officials had acted reasonably in interpreting an unsettled question of state law and that their conduct did not rise to the level of deliberate indifference or conscience-shocking behavior.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the officials’ actions did not constitute deliberate indifference under the Eighth Amendment, nor did they shock the conscience under the Fourteenth Amendment. The court emphasized that federal courts should not hold state officials personally liable for reasonable legal interpretations of unsettled state law, especially when those interpretations are made in good faith and with conventional legal reasoning. View "Swart v. Miyares" on Justia Law

Patrick Jones Jr. was hired as a probationary deputy sheriff by the Lake County Sheriff’s Office and sent to a police training academy. During his training, Jones obtained a document from his girlfriend, believing it to be a study guide, and offered to share it with classmates. The document was actually a cheat sheet for a prior version of the Illinois state law enforcement exam. After an investigation by the training institute, which concluded Jones likely did not understand the document’s true nature, the Sheriff’s Office nonetheless terminated his employment. The termination letter, authored by Undersheriff Lawrence Oliver, cited Jones’s conduct as violating the office’s code of conduct and was distributed internally and to the office’s Merit Commission. Jones later struggled to find new law enforcement employment, attributing this difficulty to the termination letter.Jones filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the termination letter was defamatory and that it deprived him of occupational liberty in violation of the Fourteenth Amendment. The district court granted summary judgment for the Sheriff’s Office and Undersheriff Oliver, finding that Jones failed to show it was virtually impossible for him to find new employment and that the statements in the letter were either true or opinion, and that Oliver was entitled to absolute immunity under Illinois law.The United States Court of Appeals for the Seventh Circuit affirmed. The court held that the Sheriff’s Office was not a proper defendant under 42 U.S.C. § 1983 because Jones did not allege a policy or custom as required for municipal liability. The court further held that Jones’s occupational liberty claim failed because there was no evidence that Undersheriff Oliver publicly disclosed the termination letter. Finally, the court held that Undersheriff Oliver was entitled to absolute immunity under Illinois law for statements made within the scope of his official duties. View "Jones v. Lake County Sheriff's Office" on Justia Law

A county public guardian sought to place an individual, A.H., under a conservatorship pursuant to the Lanterman-Petris-Short (LPS) Act, alleging that A.H. was gravely disabled due to a mental disorder. After the initial petition was filed in February 2023, the trial court imposed a temporary conservatorship. A.H. requested a trial, which by statute should have commenced within 10 days, but the trial was repeatedly continued due to court and counsel unavailability, ultimately beginning months later. As the first temporary conservatorship neared expiration, the public guardian filed a second petition and obtained a new temporary conservatorship, further extending A.H.’s involuntary confinement. A.H. objected to the continuances and sought dismissal of both petitions, arguing that the delays violated statutory deadlines and his due process rights.The Superior Court of Contra Costa County denied A.H.’s motions to dismiss, continued the trials multiple times, and ultimately dismissed the first petition at the public guardian’s request. The trial on the second petition began approximately ten weeks after the statutory deadline, and the court found A.H. gravely disabled, ordering a one-year conservatorship with various restrictions. The public guardian did not seek to renew the conservatorship after it expired.On appeal, the California Court of Appeal, First Appellate District, Division Five, held that the statutory deadline for commencing trial under the LPS Act is directory, not mandatory, and does not require automatic dismissal if missed. The court also found that, although the trial court abused its discretion by repeatedly granting continuances without good cause, this error was harmless as it did not affect the outcome of the conservatorship order. However, the appellate court concluded that the cumulative delay—over ten months of involuntary confinement before a final adjudication—violated A.H.’s due process rights, particularly since none of the delay was attributable to A.H. and he had never previously been found gravely disabled. The conservatorship order was therefore reversed. View "Conservatorship of A.H." on Justia Law

An inmate in Georgia, who practices veganism as part of his religious beliefs, was enrolled in a prison program that provided vegan meals to accommodate religious diets. He was removed from this program twice after prison officials discovered he had purchased non-vegan food items from the prison store, such as chicken soup and Cheetos. The inmate claimed he bought these items to sell to other prisoners and would have stopped if he had known it could result in removal from the program. At the time of his removals, the prison’s policy did not explicitly list non-vegan purchases as grounds for removal, though this was later added. The inmate also alleged that only Black inmates were removed from the program, while similarly situated white inmates were not.The United States District Court for the Middle District of Georgia granted summary judgment to the prison officials on the inmate’s claims under the First, Eighth, and Fourteenth Amendments, as well as most of his claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the officials were entitled to qualified immunity on the First Amendment and due process claims, that there was no evidence of discriminatory intent or similarly situated comparators for the equal protection claim, and that the non-vegan meals provided were nutritionally adequate. The court also dismissed the remaining RLUIPA claim as moot after the inmate was reenrolled in the vegan meal program.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the officials were entitled to qualified immunity, that there was insufficient evidence to support the equal protection and Eighth Amendment claims, and that the RLUIPA claims either failed on the merits or were moot because the inmate had been reinstated in the vegan meal program. View "Sumrall v. Georgia Department of Corrections" on Justia Law