Justia Government & Administrative Law Opinion Summaries

A retired teacher, Patsy Talley, received overpayments in her retirement benefits from the North Carolina Teachers’ and State Employees’ Retirement System (TSERS) for over eight years, totaling $86,173.93. When the overpayment was discovered, TSERS began reducing her monthly benefits to recoup the overpaid amount. Talley did not dispute the overpayment but argued that the recoupment process violated her due process rights because she was not provided a hearing before the reductions began.The United States District Court for the Eastern District of North Carolina dismissed all of Talley’s claims. The court held that her official capacity claims were barred by the Eleventh Amendment, her substantive due process claim failed because she received adequate post-deprivation process, and her equal protection claim did not allege a fundamental right or suspect class. The court also dismissed her individual capacity procedural due process claim, finding the defendants were entitled to qualified immunity. Additionally, the court denied Talley’s motion to amend her complaint to add new plaintiffs, citing procedural deficiencies and lack of good cause.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court agreed that the Eleventh Amendment barred the official capacity claims and that the individual capacity claims were barred by qualified immunity. The court found that Talley failed to state a substantive due process claim because she received adequate post-deprivation process and that her equal protection claim did not meet the rational basis review. The court also upheld the denial of her motion to amend the complaint, finding no abuse of discretion by the district court. View "Talley v. Folwell" on Justia Law

Former employees of Shriners Hospitals for Children were terminated for refusing to get a COVID-19 vaccination. They sued their employer, its agents, and the Executive Commissioner of Texas Health and Human Services, alleging violations of their right to refuse the vaccine under 42 U.S.C. § 1983, the Emergency Use Authorization (EUA) Statute, and various Texas state laws.The United States District Court for the Southern District of Texas dismissed all claims. It found no personal jurisdiction over the agents due to the fiduciary shield doctrine, determined that Shriners was not a state actor when it implemented the vaccination policy, and ruled that the EUA Statute did not apply. The court also dismissed the claims against the Commissioner, concluding she was not liable for failing to stop Shriners from enforcing the policy. The state-law claims were dismissed for lack of supplemental jurisdiction.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. It agreed that there was no personal jurisdiction over the agents and that Shriners was not a state actor when it adopted the vaccination policy. The court also held that the EUA Statute did not apply to Shriners in its capacity as an employer and that the Commissioner was entitled to qualified immunity because the plaintiffs did not demonstrate a clearly established right requiring her intervention. The appellate court modified the dismissal of the state-law claims to be without prejudice and affirmed the judgment as modified. View "Pearson v. Shriners Hospitals" on Justia Law

Fathiree Ali, a Muslim inmate, requested the Michigan Department of Corrections to provide him with a halal diet, which is required by his religion. The prison chaplain directed him to apply for the vegan meal option, but another official rejected his application after discovering that Ali had purchased over one hundred non-halal items from the prison commissary. Ali then sued the chaplain, the special activities coordinator, the warden, and the Michigan Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Free Exercise Clause, and 42 U.S.C. § 1983.The United States District Court for the Western District of Michigan dismissed Ali’s claims against the Department of Corrections and granted summary judgment in favor of the officials. Ali appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and dismissed Ali’s appeal in part for lack of jurisdiction and affirmed the rest of the district court’s decision. The court held that RLUIPA does not authorize money-damages claims against officials sued in their official or individual capacities. The court also found that Ali’s claims for injunctive relief against the chaplain and warden were moot because they no longer had the power to adjust his meal plan after his transfer to a different prison. Additionally, the court held that Ali’s claim for injunctive relief against the special activities coordinator was moot because the coordinator no longer worked for the Department of Corrections.The court concluded that Ali did not have a cognizable claim for injunctive or declaratory relief under RLUIPA because he had alternatives to access halal meat and could reapply for the vegan meal plan. The court also found that Ali failed to state a claim against the Michigan Department of Corrections as he did not identify a policy that violated RLUIPA. Finally, the court held that the officials were entitled to qualified immunity on Ali’s Free Exercise Clause claims under § 1983. View "Ali v. Adamson" on Justia Law

In 2023, Basin Authority, a Wyoming Child Support Agency, notified Rodolfo P. Munoz that he was in arrears on his child support obligation and began garnishing his social security. Mr. Munoz filed a complaint against the State of Wyoming, the Wyoming Department of Family Services (DFS), and some of its employees, as well as Basin Authority and several of its employees. He alleged breach of contract and violations of due process under 42 U.S.C. § 1983. The district court dismissed Mr. Munoz’s complaint after a hearing.The district court of Big Horn County granted the motions to dismiss filed by the State Defendants and the Basin Authority Defendants. The court found that Mr. Munoz had not made allegations against the State Defendants and that they were not subject to suit under § 1983 because they are not “persons” within the meaning of the statute. The court also found that a breach of contract claim is not actionable under § 1983 and that the alleged agreement was void and unenforceable. Mr. Munoz’s objection and response to the State Defendants’ proposed order on the motion to dismiss and his motion for reconsideration were denied.The Supreme Court of Wyoming reviewed the case and summarily affirmed the district court’s decision. The court noted that Mr. Munoz failed to comply with the Wyoming Rules of Appellate Procedure and did not present cogent arguments supported by pertinent authority. The court emphasized that even pro se litigants must adhere to procedural rules and present coherent arguments. The court concluded that summary affirmance was appropriate due to the deficiencies in Mr. Munoz’s brief and his failure to present relevant legal arguments. View "Munoz v. State of Wyoming" on Justia Law

At the onset of the COVID-19 pandemic, the Governor of Kentucky issued orders prohibiting mass gatherings, including religious services, and closing non-life-sustaining organizations, which included religious organizations. Maryville Baptist Church held an Easter service in defiance of these orders, leading to a lawsuit against the Governor, alleging violations of the First and Fourteenth Amendments.The United States District Court for the Western District of Kentucky initially declined to issue a preliminary injunction. However, the Sixth Circuit Court of Appeals issued a partial stay, allowing outdoor worship. Subsequently, the district court granted a preliminary injunction, permitting both indoor and outdoor worship. The Governor later allowed places of worship to reopen, and the Kentucky General Assembly limited the Governor's authority to issue similar orders in the future. The underlying action was dismissed as moot, and the Church sought attorney’s fees, which the district court denied, ruling that the Church did not prevail.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court referenced the U.S. Supreme Court's decision in Lackey v. Stinnie, which held that a party who receives a preliminary injunction but whose case becomes moot before a final judgment does not qualify as a prevailing party under 42 U.S.C. § 1988. Applying this precedent, the Sixth Circuit affirmed the district court's denial of attorney’s fees, concluding that the Church's preliminary injunction did not constitute enduring judicial relief that materially altered the legal relationship between the parties. View "Maryville Baptist Church v. Beshear" on Justia Law

Alison Mayfield, who is deaf and communicates primarily through American Sign Language (ASL), was pulled over by officers from the City of Mesa’s Police Department (MPD) for suspected reckless driving. During the traffic stop and subsequent DUI processing, Mayfield requested an ASL interpreter but was not provided one. Instead, officers used a combination of written notes, lip-reading, and gestures to communicate with her. Mayfield was ultimately charged with DUI but pleaded guilty to reckless driving.The United States District Court for the District of Arizona dismissed Mayfield’s claims under Title II of the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA), holding that her claims were barred by Heck v. Humphrey and that she failed to state a claim for which relief could be granted. Mayfield appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that Mayfield’s ADA and RA claims were not barred by Heck v. Humphrey because a ruling in her favor would not necessarily imply the invalidity of her reckless driving conviction. The court found that the district court erred in considering the original DUI charges rather than the ultimate conviction for reckless driving and that the City of Mesa had not met its burden to establish the applicability of the Heck bar.On the merits, the Ninth Circuit held that the relevant question was whether the means of communication used by the officers were sufficient to allow Mayfield to effectively exchange information during the stop and arrest. The court concluded that Mayfield failed to plead sufficient facts to establish that MPD discriminated against her by not providing a reasonable accommodation. The court affirmed the district court’s dismissal of Mayfield’s complaint without leave to amend, as amendment would be futile. View "MAYFIELD V. CITY OF MESA" on Justia Law

Two minor sisters suffered severe harm while in the custody of the Department of Children and Families (DCF). In August 2015, the older sister, then twenty-two months old, manipulated a thermostat dial from her crib, causing the bedroom to overheat. This incident led to her permanent impairment and the death of another foster child. A lawsuit was filed in the Superior Court against several defendants, including four DCF employees, alleging that their failure to fulfill their duties caused the children's harm.The Superior Court denied the employees' motion for summary judgment, which argued they were entitled to qualified immunity. The employees appealed under the doctrine of present execution, and the Supreme Judicial Court transferred the case on its own motion.The Supreme Judicial Court concluded that the DCF employees did not violate the children's substantive due process rights, as their conduct was not the proximate cause of the harm suffered. The court held that the employees' omissions, such as failing to conduct more frequent home visits or investigate the presence of a potentially dangerous individual in the foster home, did not foreseeably lead to the children's injuries. Therefore, the employees were entitled to qualified immunity, and the Superior Court's denial of summary judgment was reversed. View "Gotay v. Creen" on Justia Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

Three Coast Guard servicemembers, Eric Jackson, Alaric Stone, and Michael Marcenelle, objected to a COVID-19 vaccination mandate issued by the Coast Guard, which operates under the Department of Homeland Security. Their requests for religious accommodations were denied, and they faced reprimands for refusing the vaccination. They filed a class action lawsuit against the Secretaries of Homeland Security and Defense, the Commandant of the Coast Guard, and the Assistant Commandant for Human Resources, alleging violations of the Religious Freedom Restoration Act, the First Amendment, and the Administrative Procedure Act. They sought declaratory and injunctive relief.The United States District Court for the Northern District of Texas dismissed the case as moot after the Department of Defense rescinded its vaccination mandate, and the Coast Guard followed suit. The Plaintiffs' motion for relief from final judgment was also denied, leading to their appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s Rule 12(b)(1) dismissal de novo. The appellate court found that the case was not moot because the Coast Guard had not issued policies protecting unvaccinated servicemembers from discrimination, unlike the Navy, which had implemented such protections. The court noted that the Plaintiffs could still face adverse actions based on their vaccination status and that a court order could provide effective relief. Consequently, the Fifth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Jackson v. Noem" on Justia Law

A citizen sought access to police use of force reports under the Iowa Open Records Act. The Des Moines Police Department requires officers to complete a report whenever force is used, detailing the incident's specifics. The reports are reviewed by supervisors and used for accountability, training, and identifying trends. In 2020, 387 use of force reports were filed, with only a few resulting in disciplinary action.The Iowa District Court for Polk County granted summary judgment in favor of the citizen, ordering the City of Des Moines to disclose the use of force reports. The court found that the reports were factual accounts of incidents and not evaluative or performance records, thus not exempt from disclosure under Iowa Code section 22.7(11). The court allowed redaction of information about officer injuries or medical treatment.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the use of force reports are not exempt from disclosure under section 22.7(11) as they are factual reports, not confidential personnel records. The court also rejected the City's argument that the reports were protected under Iowa Code section 80F.1(20), as this section pertains to statements and interviews in response to complaints, not routine use of force reports. The court noted that any specific redactions could be justified on other legal grounds if necessary. View "Harrison v. Mickey" on Justia Law