Justia Government & Administrative Law Opinion Summaries

The case involves a developmentally disabled woman, referred to as A.L., who was sexually assaulted by an employee of a transportation service. The transportation service was contracted by Harbor Developmental Disabilities Foundation, a regional center under the Lanterman Developmental Disabilities Services Act. The regional center's role is to assess the needs of developmentally disabled individuals and contract with service providers to meet those needs. A.L. sued the employee, the transportation service, and the regional center, arguing that the regional center had a duty to protect her from sexual assault by the transportation service's employees.The trial court granted summary judgment in favor of the regional center, concluding that the regional center did not have a duty to protect A.L. from sexual assault by the transportation service's employees unless the regional center had actual knowledge of the employee's propensity to engage in such conduct. The trial court's decision was based on the fact that the regional center had no such knowledge in this case.On appeal, the Court of Appeal of the State of California Second Appellate District affirmed the trial court's decision. The appellate court agreed that the regional center had a duty to protect A.L. from sexual assault by the transportation service's employees only if the regional center had actual knowledge of the employee's propensity to engage in such conduct. The court concluded that imposing a broader duty on the regional center would effectively convert regional centers into insurers of all harm to consumers, which could potentially shut down these centers and deny essential services to the entire population of developmentally disabled persons. View "A.L. v. Harbor Developmental Disabilities Foundation" on Justia Law

The case involves the National Rifle Association (NRA) and Maria Vullo, the former superintendent of the New York Department of Financial Services (DFS). The NRA alleged that Vullo violated their First Amendment rights by pressuring regulated entities to disassociate from the NRA and other gun-promotion advocacy groups. The NRA claimed that Vullo threatened enforcement actions against those entities that refused to disassociate, thereby stifling the NRA's pro-gun advocacy.The District Court initially denied Vullo's motion to dismiss the NRA's First Amendment damages claims, holding that the NRA plausibly alleged that Vullo's actions could be interpreted as a veiled threat to regulated industries to disassociate with the NRA or risk DFS enforcement action. However, the Second Circuit reversed this decision, concluding that Vullo's alleged actions constituted permissible government speech and legitimate law enforcement, not unconstitutional coercion. The Second Circuit also held that even if the complaint stated a First Amendment violation, the law was not clearly established, and so Vullo was entitled to qualified immunity.The Supreme Court of the United States, however, vacated the judgment of the Second Circuit. The Supreme Court held that the NRA plausibly alleged that Vullo violated the First Amendment by coercing DFS-regulated entities to terminate their business relationships with the NRA in order to punish or suppress the NRA's advocacy. The case was remanded for further proceedings consistent with this opinion. View "National Rifle Association of America v. Vullo" on Justia Law

Wade T. Hamilton, a pediatric cardiologist, recommended a patient for a cardiac MRI scan but warned her that due to her COVID-19 vaccination, which he claimed included "magnets and heavy metals", it would be unsafe for her to enter an MRI machine. The patient's mother reported Hamilton's statements to the nurse practitioner who had referred the patient to Hamilton, leading to a report being filed against Hamilton with the Board of Licensure in Medicine. The Board, in response, opened a complaint proceeding and demanded that Hamilton undergo a neuropsychological evaluation.Hamilton challenged the Board's order in the Superior Court, arguing that the Board had overstepped its authority and violated his rights to due process and free speech. However, the Superior Court denied his petition and ruled in favor of the Board. Shortly before this decision, Hamilton's medical license in Maine expired and he did not renew it.The Maine Supreme Judicial Court dismissed Hamilton's appeal as nonjusticiable, stating that there had been no final agency action and that the challenged order was moot because Hamilton had allowed his medical license to lapse. The court also noted that Hamilton's challenge to the order directing the evaluation was fully reviewable at the conclusion of the complaint proceedings, making his petition premature. Furthermore, since Hamilton was no longer licensed in Maine, the Board no longer had authority to pursue his evaluation. The court vacated the judgment and remanded the case to the Superior Court for dismissal of the petition for judicial review as nonjusticiable. View "Hamilton v. Board of Licensure in Medicine" on Justia Law

Sarah Watkins filed a lawsuit against the City of St. Louis, Missouri, and six individual police officers under 42 U.S.C. § 1983, alleging that the officers used excessive force during a routine traffic stop. Watkins was stopped for a traffic violation near St. Louis Lambert International Airport. After she was asked to step out of her car, she was handcuffed and allegedly subjected to verbal abuse, forced into a vehicle, pepper-sprayed, and repeatedly hit on the leg with a baton. Watkins was later treated for injuries to her legs, face, and body.The district court dismissed Watkins's claims, ruling that the officers were entitled to qualified immunity on her Fourth Amendment excessive force claims. The court also dismissed the claims against the City, stating that Watkins failed to provide sufficient facts to state a claim for municipal liability under § 1983 and Monell v. Department of Social Services.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal of Watkins's claims. The court found that Watkins had sufficiently alleged a violation of her Fourth Amendment right to be free from unreasonable seizures. The court also determined that this right was clearly established at the time of the traffic stop. Therefore, the court reversed the district court's dismissal of Watkins's Fourth Amendment excessive force claims against the individual officers. However, the court affirmed the dismissal of Watkins's § 1983 claims against the City, as she had not alleged sufficient facts to support the existence of an unconstitutional policy or custom. View "Watkins v. City of St. Louis, Missouri" on Justia Law

The case involves a petition for a writ of prohibition filed by Dr. Jose Ravelo, a board-certified oral surgeon, against the West Virginia Board of Dentistry. The petitioner sought to halt the Board's ongoing investigation and any further disciplinary action against him based on his treatment of a patient in 2021. He argued that the Board violated the statutory time limitation for resolution of disciplinary actions and violated his due process rights.The Board initiated an investigation after Dr. Ravelo self-reported a complication following a surgical procedure he performed on a patient. The Board's Complaint Committee recommended filing a complaint against Dr. Ravelo, citing concerns about his standard of care. Dr. Ravelo responded to the complaint, and the Board continued its investigation.The Supreme Court of Appeals of West Virginia found that the Board complied with West Virginia Code § 30-1-5(c), which permits an extension of time for the Board to issue a final ruling. The Court held that an agreement to extend the period of time for an applicable regulatory board to issue a final ruling on a complaint is not barred by the fact that the applicable board is also the complainant. The Court also found that the Board had not violated the petitioner's constitutional right to due process. Therefore, the Court denied the petitioner's request for a writ of prohibition. View "State ex rel. Ravelo v. West Virginia Board of Dentistry" on Justia Law

The case revolves around the suicide of Donnie Clay while he was detained in the Tunica County Jail. Barbara Clay, Donnie's wife, and Whitney Jackson, Donnie's girlfriend, filed a wrongful death lawsuit against Sheriff K.C. Hamp and Tunica County. The plaintiffs alleged that the defendants violated Donnie's Fourteenth Amendment rights under 42 U.S.C. § 1983 by failing to prevent his suicide. The plaintiffs claimed that the defendants were aware or should have been aware of Donnie's vulnerability to suicide due to his history of multiple suicide attempts while detained in the jail, and that they failed to take action to prevent this risk.The defendants filed a combined motion for summary judgment, arguing that Sheriff Hamp was entitled to qualified immunity and that the County could not be held liable under § 1983 as the plaintiffs failed to establish that a policy or custom of the jail was the direct cause of Donnie's suicide. The trial court granted summary judgment in favor of the defendants, finding that Sheriff Hamp was entitled to qualified immunity and that the plaintiffs failed to identify a single policy or custom of the County that directly caused Donnie's suicide. The plaintiffs appealed the trial court's decision to grant summary judgment in favor of the County.The Supreme Court of Mississippi affirmed the trial court's decision. The court found that the plaintiffs failed to present evidence to establish that the training provided to the jail employees demonstrated deliberate indifference by the County to the potential for constitutional injuries. The court also found that a single episode of an employee's failure to follow jail policy does not establish a pattern of constitutional violations amounting to the policy of the County. Therefore, the court concluded that the trial judge did not err by granting the County's motion for summary judgment. View "Clay v. Tunica County, Mississippi" on Justia Law

The case involves a group of disabled students who sued the Superintendent of Public Instruction and the Office of the Superintendent of Public Instruction in Washington State. The students claimed that the state's practice of discontinuing special education services at the end of the school year in which a student turns 21 violated the Individuals with Disabilities Education Act (IDEA). The IDEA generally requires states to provide special education to disabled students until their 22nd birthday, but allows states to discontinue services as early as age 18 if providing special education to older students would be inconsistent with state law or practice. The students argued that because Washington offers certain adult-education programs to 21-year-olds, it should also be required to provide special education to disabled 21-year-olds.The United States District Court for the Western District of Washington denied the students' motion for a preliminary injunction, holding that the students had not shown that they would suffer irreparable harm if the injunction was not granted. The court also concluded that the students were not likely to succeed on the merits of their claim because the adult-education programs in Washington charged a tuition fee, and therefore did not constitute "free public education."The United States Court of Appeals for the Ninth Circuit vacated the district court's order and remanded the case for further proceedings. The appellate court held that the students had a high likelihood of success on the merits of their claim because the availability of the adult-education programs in Washington triggered an obligation under the IDEA to provide special education to disabled 21-year-olds. The court also found that the students would suffer irreparable harm from the denial of access to special education. The court concluded that the balance of hardships tipped in the students' favor and that an injunction would be in the public interest. View "N. D. V. REYKDAL" on Justia Law

An inmate, Timothy Finley, who suffers from severe psychiatric disorders, was placed in a heavily restrictive cell in administrative segregation for approximately three months by prison officials. Finley brought a case against the deputy wardens, Erica Huss and Sarah Schroeder, alleging violations of the Eighth Amendment and his right to procedural due process, as well as disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.The district court granted summary judgment to Huss and Schroeder on all claims. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision on Finley’s procedural due process and statutory discrimination claims. However, the court reversed the lower court's decision on Finley’s Eighth Amendment claim, finding that he presented sufficient evidence to find that the deputy wardens violated his clearly established rights. The court remanded the case for further proceedings on the Eighth Amendment claim. View "Finley v. Huss" on Justia Law

The case involves Brian Dewayne Darden-Mosby, who was convicted of two federal drug-dealing offenses. During the investigation, Drug Enforcement Agency (DEA) agents executed a search warrant for Darden-Mosby’s house and car, discovering an unregistered firearm, a money counter, drug ledgers, marijuana, and a backpack containing cocaine. They also seized $112,690 in cash found in various locations in his bedroom. After the search, police pulled over one of Darden-Mosby’s cocaine suppliers and found Darden-Mosby in the passenger seat with a bank envelope containing $2,500 in cash and two cashier’s checks totaling nearly $150,000.The United States prosecuted Darden-Mosby for various crimes based on the drugs and guns found in his house. As part of the prosecution, the government initiated criminal-forfeiture proceedings against the cash from Darden-Mosby’s bedroom, the two cashier’s checks, and the $2,500 found in Darden-Mosby’s pocket. Darden-Mosby sought to suppress the cashier’s checks and $2,500, arguing the detective’s search violated the Fourth Amendment. The district court denied the motion. The government ultimately opted not to introduce that evidence at trial, and it dismissed the criminal forfeiture claims against the two checks.A jury convicted Darden-Mosby of two drug-dealing offenses. The government declined to prosecute the forfeiture of the $2,500 in cash from the traffic stop any further but continued to pursue criminal forfeiture of the $112,690 from Darden-Mosby’s house. After a hearing and additional briefing, the court concluded the cash was connected to Darden-Mosby’s drug dealing and ordered the criminal forfeiture of the money.Separate from the government’s criminal-forfeiture actions, the DEA commenced administrative-forfeiture proceedings against the two cashier’s checks and the $2,500. These proceedings resulted in the administrative forfeiture of all three assets.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed in part and reversed in part. The court affirmed the district court’s criminal-forfeiture order with respect to the $92,470 found in the safe and shoebox at Darden-Mosby’s house but reversed with respect to the $20,220 found in and on the dresser. The court found that Darden-Mosby offered credible evidence that the $20,220 found on and in the dresser had legal sources and purposes. However, the court found that Darden-Mosby’s evidence was considerably weaker when it came to the $92,470 in the safe and shoebox. View "United States v. Darden-Mosby" on Justia Law

The case involves a dispute between Christopher Sullivan, the respondent, and several police officers and cities, the petitioners. Sullivan filed a complaint against the petitioners following a confrontation with the police officers that led to his arrest on various charges. Sullivan asserted twenty-three state law causes of action against the petitioners. In response, the petitioners filed motions to dismiss Sullivan's complaint, alleging varying theories of immunity. The Circuit Court of Jefferson County partially granted the petitioners' motions to dismiss. The court determined that the police officers were not entitled to "qualified immunity" and that the cities and their respective police departments and police chiefs were entitled to "qualified immunity" from Sullivan's negligence claims. The court also determined that Sullivan was entitled to allege claims of negligence and intentional torts from the same facts.The petitioners appealed the Circuit Court's decision to the Supreme Court of Appeals of West Virginia. The Supreme Court found that the Circuit Court erred by basing its immunity decisions on common law qualified immunity principles, which are only applicable to the State, its agencies, officials, and employees, rather than applying the provisions of the West Virginia Governmental Tort Claims and Insurance Reform Act, which govern immunity for the claims asserted against the petitioners as they are undisputedly political subdivisions and employees of political subdivisions. The Supreme Court reversed the Circuit Court's decision and remanded the case for further proceedings. View "Kent v. Sullivan" on Justia Law