Justia Government & Administrative Law Opinion Summaries

In enacting comprehensive welfare reform in 1996, Congress rendered various groups of aliens ineligible for federal benefits and also restricted states' ability to use their own funds to provide benefits to certain aliens. As a condition of receiving federal funds, Congress required states to limit eligibility for federal benefits, such as Medicaid, to citizens and certain aliens. Plaintiffs filed suit claiming that Basic Health Hawai'i violated the Equal Protection Clause of the Fourteenth Amendment because it provided less health coverage to nonimmigrant aliens residing in Hawai'i (COFA Residents) than the health coverage that Hawai'i provided to citizens and qualified aliens who are eligible for federal reimbursements through Medicaid. The court concluded that Congress has plenary power to regulate immigration and the conditions on which aliens remain in the United States, and Congress has authorized states to do exactly what Hawai'i had done here - determine the eligibility for, and terms of, state benefits for aliens in a narrow third category, with regard to whom Congress expressly gave states limited discretion. Hawai'i has no constitutional obligation to fill the gap left by Congress's withdrawal of federal funding for COFA Residents. Accordingly, the court vacated the district court's grant of a preliminary injunction preventing Hawai'i from reducing state-paid health benefits for COFA Residents because Hawai'i is not obligated to backfill the loss of federal funds with state funds and its decision not to do so was subject to rational-basis review. View "Korab v. Fink" on Justia Law

Plaintiffs filed suit against the Florida Secretary of State, arguing that Florida was violating the 90 Day Provision of the National Voter Registration Act (NVRA), 42 U.S.C. 1973gg-6(c)(2)(A), by conducting a program to systematically remove suspected non-citizens from the voter rolls within 90 days of a federal election. The 90 Day Provision requires states to "complete, not later than 90 days prior to the date of primary or general election for Federal office, any program the purpose of which is to systematically remove the names of ineligible voters from the official lists of eligible voters." Concerned about people who are not citizens casting ballots in Florida elections, the Secretary engaged in two separate programs to identify and remove non-citizens from the Florida voter rolls. Determining that the issue was not moot even if the 2012 elections have passed, the court concluded that the plain meaning of the 90 Day Provision indicates that the Secretary's actions fall under the category of "any program...to systematically remove the names of ineligible voters." Further, the statutory context and policy of the NVRA supported the court's conclusion that the plain meaning of "any program...to systematically remove the names of ineligible voters" was intended by Congress to include programs like the Secretary's. Accordingly, the court reversed and remanded. View "Arcia, et al. v. Florida Secretary of State" on Justia Law

Plaintiff, registered voters seeking to invalidate the Montana Districting and Apportionment Commission’s (Commission) assignment of two “holdover senators” in its final 2013 redistricting plan, filed a complaint against the State and Secretary of State (collectively, "State") seeking injunctive and declaratory relief. The district court granted the State’s motion for summary judgment and denied Plaintiff’s motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err in concluding that (1) the Commission did not violate the public’s “right to know”; (2) the Commission is part of the legislative branch and is not an agency, and that it is therefore exempt from statutes promulgating the right of participation; and (3) Plaintiffs’ argument that the Commission violated Plaintiffs’ right of suffrage was without merit. View "Willems v. State" on Justia Law

Plaintiff filed suit against the cities, alleging violations of the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., federal civil rights laws, and state laws stemming from the cities' demolition of his properties after declaring them nuisances. On remand, the district court concluded that plaintiff failed to state a claim under federal law and that the statute of limitations barred his FHA claims. The court concluded that the district court did not err by ordering the parties to brief the issue of whether plaintiff's complaints stated a claim under federal law; the district court properly considered the relevant evidence and did not err by excluding evidence plaintiff submitted; the district court did not err in concluding that the two-year statute of limitations barred plaintiff's FHA claims; the district court did not err in concluding that plaintiff's complaint, alleging 42 U.S.C. 1981-83 claims, failed to state a claim under federal law; and the district court did not abuse its discretion in denying motions to alter or amend. Accordingly, the court affirmed the judgment of the district court. View "Smithrud v. City of St. Paul, et al." on Justia Law

Plaintiff, the town of Hanover, filed suit against Defendant, the New England Regional Council of Carpenters, alleging that Defendant engaged in abuse of process in prior legal proceedings by maintaining the litigation, providing legal counsel, and controlling the plaintiffs’ interests, despite not being named a plaintiff in the suit. Defendant filed a special motion to dismiss pursuant to the “anti-SLAPP” statute, asserting that the town’s claims against it were solely based on Defendant’s constitutionally protected right to petition. The superior court denied Defendant’s motion, concluding that Defendant did not have standing to bring its motion under the anti-SLAPP statute. The Supreme Judicial Court reversed, holding (1) Defendant showed that the suit against it was based on protected petitioning activity; (2) the town did not meet its burden of showing that Defendant’s exercise of its right to petition was devoid of any reasonable factual support or any arguable basis in law; and (3) therefore, Defendant’s special motion to dismiss should be allowed. View "Town of Hanover v. New England Reg'l Council of Carpenters" on Justia Law

The district court held that ICP had proven that defendants' allocation of Low Income Housing Tax Credits (LIHTC) in Dallas resulted in disparate impact on African-American residents under the Fair Housing Act (FHA), 42 U.S.C. 3604(a) and 3605(a). At issue was the correct legal standard to be applied to disparate impact claims under the FHA. The court adopted the HUD burden-shifting approach found in 24 C.F.R. 100.500 for claims of disparate impact under the FHA and remanded to the district court for application of this standard in the first instance. View "Inclusive Communities Project v. TX Dept. of Housing, et al." on Justia Law

Plaintiff appealed the district court's order denying her motion for preliminary injunction of San Francisco Police Code sections 4512 and 613.10(g) on the ground that both infringed upon her Second Amendment rights. The court concluded that section 4512, which requires handguns to be stored in a locked container when not carried on the person, burdens the rights protected by the Second Amendment because storage regulations such as section 4512 are not part of a long historical "tradition of proscription;" section 4512 is not a substantial burden on the Second Amendment; and, applying intermediate scrutiny, the court concluded that section 4512 is substantially related to the important government interest of reducing firearm-related deaths and injuries. The court also concluded that section 613.10(g), which prohibits the sale of hollow-point ammunition within San Francisco, regulates conduct within the scope of the Second Amendment because restrictions on ammunition may burden the core Second Amendment right to self-defense and the record contained no persuasive historical evidence suggesting otherwise. Determining that plaintiff had standing to challenge section 613.10(g), the court concluded that section 613.10(g) is a reasonable fit to achieve its goal of reducing the legality of ammunition, and section 613.10(g) thus satisfies intermediate scrutiny. Accordingly, the court concluded that plaintiff would not succeed on the merits of her claims and affirmed the district court's denial of plaintiff's motion for preliminary injunction. View "Jackson v. City & Ctny. of San Francisco" on Justia Law

The City of Lebanon sought to annex several hundred acres of nearby property. The owners of the property subject to the annexation, including Appellees, filed a lawsuit against the City to invalidate the annexation ordinance. The trial court granted Appellees’ motion for summary judgment, concluding that the City, by intentionally manipulating the annexation boundaries to guarantee a successful annexation, violated Appellees’ constitutional rights. The court of appeals affirmed, holding that the boundaries of territory to be annexed must be “natural or regular” and that the boundaries of the proposed annexation in this case did not meet this standard. The Supreme Court reversed and declared the annexation valid, holding (1) the court of appeals erred in applying a “natural or regular” standard; and (2) the City’s annexation fully complied the the statutory requirements and did not violate Appellees’ constitutional rights. View "City of Lebanon v. Goodin" on Justia Law

Plaintiffs filed suit challenging the constitutionality of the City's Ordinance No. 2886-12, which generally prohibits targeted picketing within 50 feet of a residential dwelling. On appeal, plaintiffs challenged the district court's grant of the City's motion to dismiss. At issue are sections 62-79 and 62-77. The court concluded that the Ordinance's ban on targeted picketing, section 62-79, was content-neutral, furthered a significant government interest, was narrowly tailored, and left open ample alternate channels for speech. Therefore, section 62-79 was facially constitutional and the district court dismissed plaintiff's challenge as to section 62-79. The court concluded however, that section 62-77 granted private citizens unbridled discretion to invoke the City's power to regulate speech in public fora abutting private residences. Accordingly, the court concluded that the loitering provision was facially unconstitutional and invalid. The court affirmed in part and reversed in part. View "Bell, et al. v. City of Winter Park, FL, et al." on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, alleging, among other things, that defendants violated their First Amendment and substantive due process rights by closing down Royal Crown's day care facility in retaliation for a letter of complaint that Royal Crown sent to a New York State senator. On appeal, the individually named defendants challenged from the district court's denial of their motion for summary judgment on qualified immunity grounds and from the denial of their motion to reconsider. The court concluded that defendants were not entitled to qualified immunity solely because closing down Royal Crown may have been justified under the Health Code; defendants' motivation in closing down Royal Crown was material to Royal Crown's First Amendment and substantive due process claims and the court did not have jurisdiction to consider whether the dispute about defendants' motivation was genuine; properly assuming on this interlocutory appeal that defendants retaliated against Royal Crown for speech protected by the First Amendment, defendants' action was not objectively reasonable; Royal Crown's First Amendment and substantive due process rights to be free from retaliation and irrational government action in response to its letter to the Senator were clearly established at the time that defendants closed down plaintiff's day care facility; and therefore, defendants were not entitled to summary judgment on the basis of qualified immunity. The court affirmed the judgment of the district court. View "Royal Crown Day Care LLC v. Dept. of Health and Mental Hygiene" on Justia Law