Justia Government & Administrative Law Opinion Summaries

Respondent, a firefighter employed by the City of Rialto, brought an action under 42 U.S.C. 1983 against the City, the Fire Department, the private attorney hired by the City, and other individuals. The district court granted summary judgment to the individual defendants based on qualified immunity. The Ninth Circuit concluded that the attorney the City hired was not entitled to seek qualified immunity because he was a private attorney, not a City employee. At issue before the Court was whether an individual hired by the government to do its work was prohibited from seeking qualified immunity, solely because he worked for the government on something other than a permanent full-time basis. The Court held that a private individual temporarily retained by the government to carry out its work was entitled to seek qualified immunity from suit under section 1983. Therefore, the Court reversed the judgment of the Ninth Circuit.

The question before the Supreme Court was whether, and to what extent, a state's attorney was entitled to official immunity from civil liability for allegedly tortuous conduct concerning a local police officer. The trial court concluded that liability for the acts complained of was precluded by either qualified or absolute immunity, or was otherwise barred. In February 2010 when Plaintiff was employed as a police officer with the South Burlington Police Department, filed a complaint against Defendant, the Chittenden County State's Attorney, stating claims for defamation, intentional infliction of emotional distress, and intentional interference with Plaintiff's employment. The complaint alleged that Defendant (formerly a private lawyer and a member of what Plaintiff characterized as the Vermont "Drug Bar") harbored an animus against Plaintiff due to his police work. Plaintiff claimed that as state's attorney Defendant had "maliciously pursued a course of action . . . to undermine Plaintiff's work and credibility in the law enforcement community." As alleged in the complaint and in Plaintiff's later responses to discovery, Defendant's tortious misconduct included meeting with Plaintiff's supervisors to criticize his job performance and falsely accuse him of dishonesty; declining to file charges or seek search warrants based on Plaintiff's affidavits; threatening not to work with Plaintiff and thereby end his career if Plaintiff attempted to bypass the State's Attorney's office and obtain warrants directly from the trial court; criticizing Plaintiff's work when he was being considered by the State Police to serve on its Drug Task Force; impugning Plaintiff's honesty to other prosecutors; encouraging the filing of a civil-rights lawsuit against Plaintiff and testifying falsely in that action; and "leaking" harmful information about Plaintiff to criminal defense attorneys. Upon review, the Supreme Court concluded "[t]he trial court's ruling was sound" and affirmed the trial court's ruling that the State's Attorney was entitled to absolute immunity.

Plaintiffs, owners of two dairy operations, appealed the dismissal of their constitutional challenges to two provisions of the Milk Regulatory Equity Act of 2005 (MREA), 7 U.S.C. 608c. Plaintiffs alleged that the provisions, which subjected certain large producer-handlers of milk to contribution requirements applicable to all milk handlers, constituted a bill of attainder and violated the Equal Protection and Due Process Clauses. Because the court found that the MREA did not apply with specificity to affected persons, the court need not address whether it satisfied either of the remaining elements of a bill of attainder. Therefore, the court affirmed the district court's dismissal of plaintiffs' claim. In regards to plaintiffs' remaining arguments, the court held that mere disparity of treatment was not sufficient to state an equal protection violation. The court also found that the government provided an explanation that was not only rational on its face but also had been consistently recognized by the courts as legitimate. Further, plaintiffs failed to plead the threshold requirement of a due process claim: that the government had interfered with a cognizable liberty or property interest. Finally, the court found that the district court did not abuse its discretion by refusing to allow plaintiffs to file a supplemental complaint. Accordingly, the court affirmed the judgment of the district court.

Plaintiff sued United States Attorney General Eric Holder, alleging that the FBI refused to hire him as a special agent because of his Type I diabetes in violation of the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq. A jury found in favor of plaintiff and awarded him compensatory damages. Subsequently, the district court denied both Holder's motion for judgment as a matter of law and plaintiff's request for equitable relief. Both parties appealed. The court held that a reasonable jury could reasonably conclude that plaintiff's diabetes and treatment regiment "substantially limited" his major life activity of eating and that plaintiff was therefore disabled within the meaning of the Act. Rejecting the remaining arguments, the court held that the district court did not err in denying Holder's motion for judgment as a matter of law. The court also affirmed the district court's denial of equitable relief to plaintiff and rejected plaintiff's assertion that the district court erred in denying him front pay or instatement based on Holder's after-acquired evidence defense and in determining that plaintiff was not entitled to back pay based on the testimony of Holder's expert witness.

Respondent Michael Gendler made a public records request for location-specific accident reports from the Washington State Patrol (WSP). The WSP refused to provide the records unless Gendler certified that he would not use the records in any litigation against the State, claiming a federal statute (23 U.S.C. sec. 409) protected the records sought. WSP claimed the records were shielded because they were located in an electronic database that the Department of Transportation (DOT) utilized for purposes related to the federal hazard elimination program. Respondent then brought a suit under the PRA and argued section 409 did not apply to the WSP because it did not compile or collect the information for the hazard elimination program's purposes. Rather, the information was collected pursuant to WSP’s statutory duty under RCW 46.52.060. The trial court agreed and on summary judgment ordered WSP to produce the requested accident reports. The Court of Appeals affirmed. The Supreme Court also affirmed because section 409 does not extend to police accident reports generated and received by WSP pursuant to its own statutory duty.

The United States sued defendants, alleging they engaged in a pattern or practice of sex discrimination in the rental of housing. After a jury found for defendants, the district court granted in part defendants' motion for costs and attorneys' fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412, and the government subsequently appealed. In this case, the government brought a single pattern or practice claim. The court held that the district court should have made a single determination about whether the government's suit, as a whole, was substantially justified. The district court improperly considered the case as consisting of ten individual victims' claims for separate assessment, rather than a single pattern or practice claim. Consequently, this error required reversal.

Plaintiffs William B. Elliott, Tommy J. Evaro, and Andria J. Hernandez were all targets of investigations by a Dona Ana County grand jury. Under New Mexico law they were entitled to target notices that advised them of the right to testify before the grand jury. But the notices they received may not have complied with state law. They filed a civil-rights action under 42 U.S.C. 1983 in federal district court alleging that District Attorney Susana Martinez violated their due-process rights under the Fourteenth Amendment to the United States Constitution. The district court granted the District Attorney’s motion to dismiss on the ground that the New Mexico statute did not establish a liberty interest protected by the Fourteenth Amendment. Plaintiffs appealed. Upon review the Tenth Circuit affirmed, finding the statutory right to particular procedures was not a liberty interest under the Fourteenth Amendment.

An adult woman diagnosed with a mental illness appealed her already completed 30-day involuntary commitment to Alaska Psychiatric Institute (API), arguing the evidence did not support the superior court’s findings that: (1) she was likely to cause harm to herself or others due to her mental illness; and (2) API was the least restrictive alternative placement for her. Because Alaska's existing case law provides that an evidentiary-based "weight of the evidence" challenge to a completed involuntary commitment is moot absent accompanying legal issues appropriate for decision under the mootness doctrine's public interest exception, the Supreme Court asked the parties to submit supplemental briefing on mootness. As a result, the Court addressed a question not directly raised in earlier cases: should the Court's application of the mootness doctrine in this context accommodate the importance of collateral consequences arising from an involuntary commitment? The Court answered that question "yes" and therefore reached the merits of this appeal. On the merits, the Court affirmed the superior court's involuntary commitment order.

Plaintiff-Appellant Michael Sabourin sued the University of Utah in the United States District Court for the District of Utah, claiming, among other things, that it had violated the Family and Medical Leave Act (FMLA) by deciding to eliminate his position and then fire him for cause while he was on leave for childcare in 2006. The district court granted the University summary judgment. Plaintiff appealed the dismissal of his FMLA claims. Upon review, the Tenth Circuit affirmed: all of Plaintiff’s claims failed because the undisputed facts showed that the University’s adverse decisions were not based on Plaintiff’s taking FMLA leave. The decision to eliminate his position was made before he sought FMLA leave; and he was fired for engaging in a course of insubordination.

The district court ordered the Governor of the State of New York and various state commissioners and agencies to make certain modifications to the State's mental health system to ensure compliance with 28 C.F.R. 35.130(d) - the so-called "integration mandate" of Title II of the Americans with Disabilities Act, 42 U.S.C. 12132, and Section 504 of the Rehabilitation Act, 29 U.S.C. 794. The court held that DAI, a nonprofit organization contracted to provide services to New York's Protection and Advocacy System under the Protection and Advocacy for Individuals with Mental Illness Act, 42 U.S.C. 10801 et seq., lacked standing under Article III to bring the claim. The court also held that the intervention of the United States after the liability phase of the litigation had concluded was insufficient to cure the jurisdictional defect created by DAI's lack of standing. Therefore, the court vacated the judgment and remedial order and dismissed for want of jurisdiction.