Justia Government & Administrative Law Opinion Summaries

Anthony Rojas, a student at the University of Florida, filed a class action lawsuit against the University of Florida Board of Trustees. Rojas claimed that the University breached its contract by suspending on-campus services and closing facilities during the COVID-19 pandemic, despite students being required to pay mandatory fees for these services. He also alleged that the University failed to refund these fees. The complaint included a spring 2020 tuition statement, a general statement of tuition and fee estimates for the 2019-2020 academic year, and the University’s financial liability agreement.The trial court dismissed the unjust enrichment claim but denied the University’s motion to dismiss the breach of contract claim, ruling that the complaint adequately pleaded the existence of an express contract. The University appealed, and the First District Court of Appeal reversed the trial court’s decision, holding that the claims were barred by sovereign immunity. The First District concluded that the contract alleged by Rojas did not constitute an express written contract sufficient to overcome sovereign immunity.The Supreme Court of Florida reviewed the case and quashed the First District’s decision. The Court held that the waiver-by-contract doctrine does not preclude claims based on the breach of implied covenants or conditions that do not conflict with express contract provisions. The Court found that the First District erred in requiring extraordinary specificity in government contracts and in failing to recognize permissible implied covenants. The case was remanded for further proceedings consistent with this opinion. View "Rojas v. University of Florida Board of Trustees" on Justia Law

Plaintiffs, limited liability companies, filed class action lawsuits in the United States District Court for the District of Maryland seeking relief under the Medicare Secondary Payer (MSP) provisions. These provisions make Medicare a secondary payer when a beneficiary has other insurance coverage. Plaintiffs obtained assignments from Medicare Advantage Organizations and other secondary payers to seek reimbursement from primary payers like the defendants, Government Employees Insurance Company and its affiliates (GEICO). Plaintiffs had no preexisting interest in the claims and were compensated on a contingency basis.The United States District Court for the District of Maryland denied GEICO's motion to dismiss the case, which argued that the assignments were void as against Maryland public policy based on the doctrines of maintenance, champerty, and barratry. The court found no clear statement of Maryland law on this issue and certified questions to the Supreme Court of Maryland.The Supreme Court of Maryland held that Plaintiffs did not violate Maryland’s barratry statute, which prohibits soliciting another person to sue for personal gain without an existing relationship or interest. Plaintiffs did not solicit secondary payers to file lawsuits but obtained the right to sue in their own names through assignments. The court also held that the common law doctrines of maintenance, champerty, and barratry, to the extent they still apply, do not invalidate Plaintiffs’ assignments. The court concluded that the assignments are not void as against public policy and did not address the enforceability of choice-of-law provisions in the agreements. View "GEICO v. MAO-MSO Recovery II" on Justia Law

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law

N.S. was arrested for robbery and destruction of property and was released on his own recognizance by a Magistrate Judge. However, before he could leave the courthouse, U.S. Marshals detained him based on an ICE detainer. N.S. filed a class complaint alleging that the Marshals acted beyond their statutory authority by making a civil immigration arrest, violating the Administrative Procedure Act.The United States District Court for the District of Columbia certified the proposed class and granted N.S.'s request for a permanent injunction, prohibiting Marshal Dixon and his agents from arresting and detaining criminal defendants in the Superior Court for suspected civil immigration violations. The court held that the Marshals were not authorized to make civil immigration arrests as they had not undergone the required training. The court also found that the 2002 Order delegating authority to the Marshals lacked sufficient legal support.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Marshals were not authorized to make civil immigration arrests due to the lack of required training. However, the court found that the class-wide injunction issued by the district court was barred by 8 U.S.C. § 1252(f)(1), which prohibits lower courts from enjoining the operation of certain immigration provisions. The court vacated the injunction and remanded the case to the district court to reconsider the appropriate remedy. View "N.S. v. Dixon" on Justia Law

In 2018, South Carolina excluded Planned Parenthood from its Medicaid program, citing state law prohibiting public funds for abortion. Planned Parenthood and patient Julie Edwards sued, claiming the exclusion violated the Medicaid any-qualified-provider provision, which allows Medicaid beneficiaries to obtain services from any qualified provider. Edwards preferred Planned Parenthood for gynecological care but needed Medicaid coverage. They filed a class action under 42 U.S.C. §1983 to enforce rights under the federal Medicaid statutes.The district court granted summary judgment for the plaintiffs and enjoined the exclusion. The Fourth Circuit affirmed. The Supreme Court granted certiorari, vacated, and remanded the case in light of Health and Hospital Corporation of Marion Cty. v. Talevski, which addressed whether another spending-power statute created §1983-enforceable rights. On remand, the Fourth Circuit reaffirmed its decision.The Supreme Court of the United States held that Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under §1983. The Court emphasized that spending-power statutes rarely create enforceable rights and that the any-qualified-provider provision lacks the clear rights-creating language necessary to support a §1983 action. The Court reversed the Fourth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Medina v. Planned Parenthood South Atlantic" on Justia Law

Simon Soto, a Marine Corps veteran, served from 2000 to 2006 and was medically retired due to post-traumatic stress disorder (PTSD). In 2016, Soto applied for combat-related special compensation (CRSC) and was approved, but his retroactive compensation was limited to six years due to the Barring Act's limitations period. Soto filed a class-action lawsuit arguing that the CRSC statute should displace the Barring Act's limitations period.The United States District Court for the Southern District of Texas granted summary judgment in favor of Soto and the class, holding that the CRSC statute provides its own settlement mechanism, thus displacing the Barring Act. However, the United States Court of Appeals for the Federal Circuit reversed this decision, stating that the CRSC statute does not explicitly grant settlement authority and therefore cannot displace the Barring Act.The Supreme Court of the United States reviewed the case and held that the CRSC statute does confer authority to settle CRSC claims, thereby displacing the Barring Act’s settlement procedures and limitations period. The Court reasoned that the CRSC statute authorizes the Secretary concerned to determine both the validity of CRSC claims and the amount due, creating a comprehensive compensation scheme. Consequently, the Supreme Court reversed the Federal Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Soto v. United States" on Justia Law

Plaintiffs, Glacier County taxpayers, alleged that the County and its Commissioners unlawfully made expenditures or disbursements of public funds or incurred obligations in excess of total appropriations, violating Montana law. The case originated from a 2015 lawsuit by Plaintiff Elaine Mitchell, who claimed the County and State failed to comply with the Single Audit Act and the Local Government Budget Act. An independent audit revealed deficit balances in many county funds, prompting the lawsuit. The plaintiffs sought various forms of relief, including declarations of non-compliance with accounting standards and laws ensuring government financial accountability.The Ninth Judicial District Court granted partial summary judgment to Plaintiffs on the issue of the County's improper liquidation of a tax protest fund. Plaintiffs then filed a motion to certify Count II as a class action, which the District Court granted, defining the class as property taxpayers of Glacier County who paid taxes from 2012 to 2020. The County appealed the class certification order and the denial of its motion to dismiss for lack of standing.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decisions. The Court held that Plaintiffs had standing, as they alleged concrete economic injuries from the County's actions, such as increased tax obligations and loss of county services. The Court also found that the class met the prerequisites for certification under M. R. Civ. P. 23(a), including numerosity, commonality, typicality, and adequate representation. The Court ruled that common questions of law and fact predominated over individual questions, making a class action the superior method for adjudicating the controversy. The class certification was affirmed, and the case was remanded for further proceedings. View "Gottlob v. DesRosier" 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

The City of East Lansing entered into an agreement with the Lansing Board of Water and Light (LBWL) in 2016, which included a franchise fee to be charged to LBWL consumers residing within the City. The fee was collected by LBWL and remitted to the City. Plaintiff James Heos, representing a class of LBWL consumers, filed a complaint against the City, alleging that the franchise fee was an illegal tax under the Michigan Constitution's Headlee Amendment and other state laws.The trial court granted summary disposition in favor of the plaintiff on most counts, ruling that the franchise fee was an illegal tax. The Michigan Court of Appeals reversed this decision, directing the trial court to grant summary disposition in favor of the City, concluding that the plaintiff was not a taxpayer and thus his claim was time-barred.The Michigan Supreme Court reviewed the case and held that the franchise fee was indeed a tax because it was used for general revenue-raising purposes, was not proportionate to any costs incurred by the City, and was not voluntary. The Court further held that the plaintiff was a taxpayer because the legal incidence of the fee fell on the LBWL consumers, not LBWL itself. The Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings, allowing the plaintiff to pursue his Headlee Amendment claim. View "Heos v. City Of East Lansing" on Justia Law

Plaintiffs, a class of individuals, filed mortgage foreclosure complaints in Illinois circuit courts and paid "add-on" filing fees mandated by section 15-1504.1 of the Code of Civil Procedure. They challenged the constitutionality of these fees, asserting that the statute violated the free access clause of the Illinois Constitution. The Illinois Supreme Court previously agreed, declaring the statute unconstitutional and affirming an injunction against its enforcement.The Will County circuit court initially certified the class and granted partial summary judgment, finding the statute unconstitutional. The appellate court reversed, and the case was remanded. On remand, plaintiffs pursued a refund of the fees. The circuit court dismissed the refund claim, citing sovereign immunity, which bars claims against the State. The appellate court reversed, holding that the circuit court had jurisdiction under the officer-suit exception to sovereign immunity, which allows suits against state officials for unconstitutional actions.The Illinois Supreme Court reviewed the case and held that while the officer-suit exception allowed the circuit court to enjoin the enforcement of the unconstitutional statute, it did not apply to the refund claim. The court determined that the refund claim was a retrospective monetary award to redress a past wrong, which falls under the jurisdiction of the Court of Claims, not the circuit court. Consequently, the Illinois Supreme Court reversed the appellate court's judgment and affirmed the circuit court's dismissal of the refund claim. View "Walker v. Chasteen" on Justia Law