Justia Government & Administrative Law Opinion Summaries

After Scott Schuette, who was working as a police officer at the time, responded to an accident at the local high school he began experiencing mental health problems. Schuette was later diagnosed with post-traumatic stress disorder (PTSD). Schuette filed a claim petition seeking workers’ compensation benefits for PTSD. A compensation judge denied Schuette’s claim, finding that Schuette’s PTSD lacked a physical component and was thus not a compensable injury under Minnesota law. The Workers’ Compensation Court of Appeals (WCCA) affirmed, determining (1) to be compensable under Lockwood v. Independent School District No. 877, an injury must include a physical component; and (2) the compensation judge’s findings that Schuette’s PTSD did not result in a physical brain injury had substantial evidentiary support. The Supreme Court affirmed, holding (1) the compensation judge’s findings were not manifestly contrary to the evidence; and (2) applying the doctrine of stare decisis, Schuette’s request to overrule Lockwood was declined. View "Schuette v. City of Hutchinson" on Justia Law

Plaintiff filed suit challenging his arrests for refusing to obey Officer Early's repeated orders to confine his leafleting to the area designated for protest activities outside the First Mariner Arena in Baltimore. The designated protest area was defined by a written policy of the City and the BCPD. The court held that the policy was facially valid under the First Amendment as a reasonable time, place, and manner restriction. The court found that the district court committed no reversible error as to plaintiff's remaining claims. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendants. View "Ross v. Early" on Justia Law

United Public Workers, AFSCME, Local 646, AFL-CIO (“UPW”) filed an action on behalf of the employees it represented, alleging (1) then-Governor Lingle and members of her administration retaliated against UPW members for filing a lawsuit opposing her statewide furlough plan; and (2) the State was unlawfully privatizing positions customarily performed by civil servants under the merit system. The circuit court dismissed the complaint based on a lack of jurisdiction. The intermediate court of appeals (ICA) vacated the circuit court’s judgment and remanded with instructions to stay the action pursuant to the primary jurisdiction doctrine so the parties could pursue appropriate administrative remedies before the Hawaii Labor Relations Board (HLRB). The Supreme Court primarily affirmed, holding (1) the ICA did not err in concluding that the primary jurisdiction doctrine was applicable to UPW’s retaliation claims because the claims required the resolution of issues that have been placed within the special competence of the HLRB, and that a stay, rather than a dismissal, was appropriate under the circumstances; and (2) the primary jurisdiction doctrine did not apply to UPW’s privatization claims, and therefore, the circuit court erred in dismissing these claims, and the ICA erred in referring the claims to the HLRB. Remanded. View "United Pub. Workers, AFSCME, Local 636, AFL-CIO v. Abercrombie" on Justia Law

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm'n" on Justia Law

Plaintiff filed suit against her former employer alleging the employer violated both federal law and the Oklahoma Anti-Discrimination Act (OADA) in terminating her employment. Specifically, she alleged her employer discriminated against her on the basis of her age and gender. Anticipating employer's defense that section 1350 of the OADA limited damages for discrimination claims, plaintiff alleged the damage limitations in the OADA were unconstitutional under Oklahoma's prohibition against special laws. Citing the lack of Oklahoma precedent on this issue, the district court certified the question of whether the damage provisions in section 1350 of the OADA are unconstitutional under Article V, sections 46 and 59 of the Oklahoma Constitution to the Supreme Court. Upon review, the high court held that the damage provisions in section 1350 were not unconstitutional. View "MacDonald v. Corporate Integris Health" on Justia Law

Plaintiff filed suit against the city building inspector under 42 U.S.C. 1983, alleging violations of his First Amendment rights. The district court granted summary judgment to defendant and the city, dismissing plaintiff's suit with prejudice. The court affirmed, concluding that, while the inspector was acting inappropriately, he did not violate plaintiff's First Amendment rights where the potential chilling effect of the inspector's instruction to a city employee to call the police when plaintiff wanted to file a grievance against the inspector was mitigated by the fact that the other city employees present did not echo the inspector's attitude. View "Scheffler v. Molin, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against police officers and the city after the officers entered her home without a warrant and shot her five or six times when she reacted violently to the officers' presence, grabbing a knife and threatening to kill the officers. Plaintiff, a woman in her mid-50s suffering from a mental illness, told the officers that she did not want to be taken to a mental health facility. The court affirmed in part, holding that the officers were justified in entering plaintiff's home initially under the emergency aid exception because they had an objectively reasonable basis to believe that she was in need of emergency medical assistance and they conducted the search or seizure in a reasonable manner up to that point. The court held that there were triable issues of fact as to whether the second entry violated the Fourth Amendment where a jury could find that the officers acted unreasonably by forcing the second entry and provoking a near-fatal confrontation. The court further held that there were triable issues of fact as to whether the officers used excessive force by resorting to deadly force and shooting plaintiff. Finally, the court held that the district court properly rejected claims of municipal liability; the court joined the majority of circuits that have addressed the issue and held that Title II of the Americans with Disabilities Act, 42 U.S.C. 12132, applied to arrests; on the facts presented here, there was a triable issue as to whether the officers failed to reasonably accommodate plaintiff's disability; and the court vacated summary judgment on plaintiff's state law claims and remanded for further proceedings. View "Sheehan v. City & Cnty. of San Francisco" on Justia Law

Plaintiffs filed suit against police officers, the County, and the City after officers assaulted them outside of a nightclub. The court affirmed the district court's post-trial determination that plaintiffs' complaint sufficiently stated a cause of action for bystander liability under 42 U.S.C. 1983. In doing so, however, the court vacated and remanded the district court's summary judgment ruling to the opposite effect. The only defendant that the reversal of this issue impacted was Officer Lowery because he was the only defendant against whom the section 1983 count survived dismissal. The court affirmed the district court's grant of summary judgment to Officer Adey on the excessive force and battery counts with respect to all plaintiffs and the grant of summary judgment to Officer Lowery in his alleged role as a principal actor on the section 1983 count with respect to Plaintiffs Howard and Barnett. Because Officer Adey was not liable for either the battery or the excessive force counts as to any of plaintiffs, the County was also not liable under the Maryland constitutional count on the theory of vicarious liability. Finally, the district court did not abuse its discretion by denying plaintiffs' Rule 59(e) motion to alter or amend the ruling on summary judgment. Accordingly, the court affirmed in part, reversed in part, and remanded with instructions. View "Stevenson v. City of Seat Pleasant, MD" on Justia Law

The West Virginia Division of Motor Vehicles (DMV) revoked the driver’s licenses of Respondents following their arrests for driving under the influence of alcohol. The Office of Administrative Hearings (OAH) reversed the revocation of Respondents’ driver’s licenses, concluding that the evidence did not establish that Respondents had been lawfully arrested for driving under the influence of alcohol. The circuit court denied the DMV’s petitions for judicial review. The Supreme Court reversed and remanded for reinstatement of the respective DMV orders revoking Respondents’ driver’s licenses, holding that Respondents were lawfully arrested, and the OAH’s findings to the contrary were clearly wrong. View "Dale v. Odum" on Justia Law

North Carolina's House Bill 289 authorized the state's Division of Motor Vehicles to issue, among other specialty license plates, a "Choose Life" plate. However, this law authorized no pro-choice specialty license plate. North Carolina vehicle owners who wanted a pro-choice specialty plate, along with the ACLU, filed suit challenging the statute. North Carolina argued that it could so discriminate because specialty plate messages constituted pure government speech free from First Amendment viewpoint-neutrality constraints. The court concluded that, because the specialty plate speech at issue implicated private speech rights and was not pure government speech, North Carolina's authorizing a "Choose Life" plate while refusing to authorize a pro-choice plate constituted viewpoint discrimination in violation of the First Amendment. Accordingly, the court affirmed the district court's grant of summary judgment and a permanent injunction in favor of the vehicle owners and the ACLU. View "American Civil Liberties Union v. Tata" on Justia Law