Justia Government & Administrative Law Opinion Summaries

This case concerned the Washington State Grange's proposed People's Choice Initiative of 2004, or Initiative 872. I-872 created a "top two" primary in which the primary served as a means of winnowing the candidates to two rather than selecting party nominees. At issue was whether the State of Washington had designed its election ballots in a manner that eliminated the risk of widespread voter confusion, a question left unresolved in Washington State Grange v. Washington State Republican Party. The court held that the state had done so. The ballots, and related informational material, informed voters that, although each candidate for partisan office could specify a political party that he or she preferred, a candidate's preference did not imply that the candidate was nominated or endorsed by the party, or that the party approved of or associated with that candidate. Given the design of the ballot, and in the absence of evidence of actual voter confusion, the court held that Washington's top primary system, as implemented by the state, did not violate the First Amendment associational rights of the state's political parties. The court also affirmed the district court's dismissal of plaintiffs' ballot access and trademark claims. The court reversed the district court's order granting the state's request for reimbursement of attorney's fees paid in accordance with a 2006 stipulation.

Petitioner-Appellant Spence Koenig appealed a district court's judgment that affirmed the Department of Transportation's decision to suspend his driving privileges for ninety-one days. Petitioner was pulled over by a state trooper for speeding and for expired tabs. Petitioner agreed to perform a field sobriety test and failed it. The trooper told Petitioner's girlfriend that Petitioner would be released when someone over eighteen years old came to pick Petitioner up. Petitioner argued he was denied an opportunity to obtain an independent sobriety test after he made sufficient arrangements for one because he was held in custody for over three hours with no attempt or offer to transport him to the hospital for the additional test. Petitioner asserted that "the responsibility of securing [his] right to an independent blood test became that of law enforcement holding him in custody[,]" when it became apparent his ride was not coming. Finding that the officers did not have a duty to transport Petitioner to the hospital to obtain the independent test, the Supreme Court affirmed the Department's decision.

This civil action arose out of events that occurred on the first day of the 2008 Republican National Convention in St. Paul, Minnesota. 32 people filed suit under 42 U.S.C. 1983 against six police officers and the City of St. Paul, alleging violations of their rights under the First and Fourth Amendments. Plaintiffs subsequently appealed the dismissal of their claims against five officers and the City. The court affirmed the district court's conclusion that the officers were entitled to qualified immunity for the seizures; the record did not show that any defendant directly used force against any plaintiff; and Sergeant Axel Henry was entitled to qualified immunity. The court also held that the district court correctly granted summary judgment for the officers on plaintiffs' claims that the officers arrested them in retaliation for exercising their First Amendment rights. The court further held that the district court correctly granted summary judgment in favor of the City where a Senior Commander's actions were not sufficient to impose liability on the City.

Plaintiff-Appellant Stuart Guttman, MD had a history of depression and post-traumatic stress disorder. His medical license was "qualified" by the New Mexico Board of Medical Examiners, which subjected him to quarterly psychiatrist reports and other conditions. The Board removed the qualifications in 1995. Several years later, the Board began receiving complaints about Plaintiff. The Board reviewed Plaintiff's conduct in his practice, and in 2000, the Board summarily suspended Plaintiff's medical license after finding "clear and convincing" evidence that having Plaintiff continue his practice would be an "imminent danger to public safety." In 2001, after recognizing an extensive pattern of disruptive and abusive behavior in dealing with patients and healthcare professionals, the Board revoked Plaintiff's license. The question presented in this appeal before the Tenth Circuit was whether the Eleventh Amendment protected New Mexico from a suit for money damages under Title II of the Americans With Disabilities Act (ADA). Plaintiff challenged the Board's findings in state court, asserting that the Board's actions violated Title II of the ADA. The State court refused to consider Plaintiff's claim, and the New Mexico Supreme Court affirmed. Upon review, the Tenth Circuit concluded that the Eleventh Amendment indeed protects New Mexico from suit on sovereign immunity grounds. Accordingly, the Court found that the district court did not err in dismissing Plaintiff's ADA claim.

In an appeal from the district court's dismissal of a 42 U.S.C. 1983 action on grounds of standing and Younger v. Harris abstention, plaintiff argued that it had standing to assert various constitutional claims and that the district court also erred in abstaining in deference to the pending state-court actions regarding whether the minor children of the members of the church were neglected or abused. Defendants contended that the district court relied on abstention only with respect to the individual plaintiffs and that the church did not have standing to assert claims alleging a deprivation of its own federal rights much less those of its individual members. The court agreed that the district court applied abstention with respect to individual plaintiffs, and that it dismissed the church solely for lack of standing. Without reaching the question of standing at the pleading stage, however, the court affirmed because the court's analysis of Younger abstention with respect to the two individual plaintiffs was equally applicable to the church.

Plaintiff appealed the district court's dismissal of his 42 U.S.C. 1983 claims against the county and the sheriff. At issue was whether plaintiff's due process rights were violated when the sheriff induced plaintiff to plead guilty to a pending felony charge of terroristic threatening in December 1989. The court concluded that the alleged coercion did not render plaintiff's plea involuntary; there was no imposition of section 1983 liability on a state actor for coercing or inducing a guilty plea that was later determined not to be knowing and involuntary; an official holding a criminal defendant in pretrial custody could reasonably assume that the trial court would properly determine whether the defendant was competent to stand trial or plead guilty; and plaintiff failed to present evidence from which a reasonable jury could conclude that the sheriff's statements were the proximate cause of the violation of plaintiff's constitutional rights. The court held that because plaintiff failed to establish a violation of his constitutional rights by the sheriff, the district court properly dismissed plaintiff's official capacity claims against the sheriff and the county.

This case involved Commonwealth Care, a state-initiated program that provided structured premium assistance for low-income Massachusetts residents. In 2009, the Legislature made certain changes to the eligibility requirements of Commonwealth Care, enacted in a two-part supplemental appropriation for fiscal year 2010. Section 31(a) of the appropriation excluded all aliens who were federally ineligible under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 8 U.S.C. 1601-1646, from participation in Commonwealth Care. Plaintiffs were individuals who either have been terminated from Commonwealth Care or have been denied eligibility solely as a result of their alienage. The court held that section 31(a) could not pass strict scrutiny and that the discrimination against legal immigrants that its limiting language embodied violated their rights to equal protection under the Massachusetts Constitution.

Plaintiff appealed the district court's order affirming the Commissioner's denial of her application for supplemental security income (SSI). The court found that substantial evidence supported the ALJ's conclusion that plaintiff was not disabled within the meaning of the Social Security Act, 42 U.S.C. 301 et seq. Accordingly, the court affirmed the district court's grant of judgment on the pleadings in favor of the Commissioner.

Plaintiffs, Matthew Cantrell's family, filed suit against the City of Murphy and several of its officers after 21-month-old Matthew died of accidental hanging when he was found tangled up in a soccer net in the back yard of his home. This was an interlocutory appeal from the denial of qualified immunity. The court rejected plaintiffs' argument that the officers deprived Matthew of his due process rights under DeShaney v. Winnebago County Department of Social Services, where plaintiffs failed to establish that the officers had a special relationship with Matthew when they separated him from his mother. The court also held that because the officers had probable cause to detain Matthew's mother, the district court did not err in granting the officers summary judgment on this portion of plaintiffs' Fourth Amendment claim. Accordingly, the court reversed and remanded for further proceedings.

Pro se Plaintiff-Appellant Richard Dumas appealed the dismissal of his workplace discrimination suit against Proctor and Gamble (P&G). Plaintiff was employed as a contractor assigned to work at P&G's Kansas City manufacturing plant in 2005. Between 2005 and 2007, Plaintiff alleged he was subjected to discrimination in the workplace including the use of racial epithets, misuse of company disciplinary proceedings, and an incident in which a chair was pulled away as Dumas was attempting to sit on it. Dumas resigned in November of 2007. In 2011, he filed a charge with the Equal Employment Opportunity Commission (EEOC) alleging discrimination. The EEOC closed the claim as untimely. Plaintiff then filed a complaint in district court against P&G, and P&G moved to dismiss, alleging Plaintiff failed to timely exhaust his administrative remedies. Plaintiff responded that he was given bad advice by an unnamed EEOC agent. The district court concluded that Dumas failed to meet the narrow requirements for equitable tolling and dismissed the claim. Finding that Plaintiff failed to carry his burden of establishing that an EEOC agent actually misled him, and insufficiently present his state law claims, the Tenth Circuit affirmed the district court's judgement in dismissing Plaintiff's case.