Justia Government & Administrative Law Opinion Summaries

Three individuals filed a class action lawsuit against San Francisco, challenging new water rates adopted by the city’s Public Utility Commission in May 2023. The plaintiffs alleged that the new rates violated Proposition 218 of the California Constitution by including costs unrelated to the actual provision of water service, resulting in charges that exceeded the cost of service. Before adopting the new rates, the city provided required notice to ratepayers, including information about a 120-day period for legal challenges under the applicable validation statutes. The plaintiffs sought a refund, declaratory and equitable relief, and a writ of mandate.After the class action was filed, the City litigated the case for over a year. It participated in discovery, case management, and even moved for summary judgment, without initially arguing that the suit was procedurally improper. Eventually, the City moved for judgment on the pleadings, arguing that plaintiffs’ action was subject to the validation statutes, specifically Government Code section 53759 and Code of Civil Procedure sections 860 et seq., which require reverse validation actions attacking agency matters like water rates to be brought within 120 days and with specific notice by publication to all interested parties. The trial court (San Francisco County Superior Court) agreed with the City, finding the statutes mandatory and jurisdictional, and dismissed the case for failure to comply with the procedural requirements, including timely filing and appropriate notice.On appeal, the California Court of Appeal, First Appellate District, Division Two, reviewed the judgment de novo. The court held that compliance with the validation statutes was mandatory and jurisdictional. Plaintiffs’ failure to file a proper reverse validation action and to provide notice by publication deprived the court of jurisdiction. The court rejected arguments that the City had waived these requirements or that good cause existed for noncompliance. The judgment in favor of the City was affirmed. View "Toy v. City & County of S.F." on Justia Law

Several plaintiffs brought a class action lawsuit against a city, challenging the validity of recently adopted water rates. They alleged that the city’s new rates, implemented by a resolution passed in May 2023, violated Proposition 218 by including costs for public fire service, resulting in charges exceeding the actual cost of water service. Prior to filing suit, the plaintiffs submitted claims under the Government Claims Act, which were denied. The plaintiffs sought refunds, declaratory relief, equitable relief, and a writ of mandate.After the city litigated the case for more than a year, including discovery and other pretrial activities, it moved for judgment on the pleadings, arguing that plaintiffs failed to bring a reverse validation action as required by Government Code section 53759 and Code of Civil Procedure sections 860 et seq. The San Francisco County Superior Court granted the city’s motion, holding that the validation statutes applied, were both mandatory and jurisdictional, and that plaintiffs had not complied with them in two ways: their suit was time-barred and they failed to follow proper notice procedures, including service by publication.On appeal to the California Court of Appeal, First Appellate District, Division Two, plaintiffs argued that the city had waived the validation requirements by litigating the case and that their action was timely. The appellate court reviewed the matter de novo and held that the validation statutes were mandatory and jurisdictional for challenges to water rates, and plaintiffs’ failure to comply with statutory procedures—including timely filing and notice by publication—was fatal to their claims. The court rejected arguments regarding waiver, good cause, and belated publication, ultimately affirming the trial court’s order and concluding that the procedural requirements for reverse validation actions must be strictly followed. View "Toy v. City and County of S.F." on Justia Law

A resident of St. Louis brought a class action lawsuit against the city, seeking a refund of fees paid for solid waste services. The plaintiff alleged that these fees were collected under the mistaken belief that the city was providing separate recycling and yard waste collection, which the city either failed to provide or did not provide consistently. The city had implemented a monthly solid waste services fee in 2010, increased it in 2017, and included the fee in residents’ water bills. Although the city at times collected recyclables and yard waste separately, it often did not, and ultimately terminated the program in 2025. The plaintiff argued that the city unjustly retained fees for services it did not render, seeking damages for herself and other residents.The Circuit Court of the City of St. Louis denied the city’s motion to dismiss, finding that the plaintiff’s claim for “money had and received” could proceed. The city then sought a writ of prohibition from the Missouri Court of Appeals, which was denied. The city subsequently sought relief from the Supreme Court of Missouri.The Supreme Court of Missouri held that the city is protected by sovereign immunity and that section 432.070 of the Missouri Revised Statutes bars the claim. The court found that the plaintiff’s allegations did not plead facts that would establish an exception to sovereign immunity for her claim and that no statutory or recognized common law exception applied. The court also concluded that the proprietary function exception did not apply, as solid waste collection is a governmental function. The court made its preliminary writ of prohibition permanent, directing that the plaintiff’s claim be dismissed. View "State ex rel. City of St. Louis vs. Whyte" on Justia Law

A public agency adopted an ordinance to increase water service rates after following procedural steps, such as conducting a cost-of-service analysis, notifying the public, and holding hearings as required by Proposition 218 of the California Constitution. After adopting the new rates, the agency initiated a validation action in court to confirm the validity of the ordinance, providing notice to interested parties by publication in a local newspaper, as authorized by statute. No one responded to contest the action within the required time, so the court entered default judgment upholding the ordinance.Subsequently, an individual who had previously submitted administrative claims to the agency challenging the rates filed a class action and mandamus lawsuit seeking refunds and declaratory and injunctive relief, alleging violations of Proposition 218 and constitutional rights. The agency responded with a demurrer, arguing that the plaintiff's claims were barred by the prior validation judgment and the statutory scheme requiring such challenges be brought through validation procedures. The Marin County Superior Court agreed, sustaining the demurrer without leave to amend and finding that the plaintiff's opportunity to challenge the rates had been foreclosed by the unchallenged validation judgment.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that under Government Code section 53759 and the related validation statutes, any legal challenge to ordinances adopting water service fees must be brought through specified validation proceedings, including constitutional claims. Since the plaintiff neither intervened in the agency's validation action nor filed a timely reverse validation action, her claims were barred. The court also found that due process was satisfied by the published notice required by statute, and that mandamus proceedings are not exempt from these requirements. The appellate court affirmed the judgment in favor of the agency. View "Hiller v. Marin Municipal Water Dist." on Justia Law

Several researchers at the University of California received multi-year federal grants from agencies including the Environmental Protection Agency, the National Science Foundation, and the National Endowment for the Humanities. In April 2025, these agencies terminated the research grants by issuing form letters, citing shifts in agency priorities and referencing multiple Executive Orders issued by the President, some of which explicitly aimed to eliminate diversity, equity, and inclusion (DEI) and related initiatives from the federal government. The affected researchers alleged these terminations resulted in lost funding, harm to their reputations, and disruption to their projects, with no ready alternative sources of support.The researchers filed a class action lawsuit in the United States District Court for the Northern District of California, asserting constitutional and statutory claims, including violations of the First Amendment and the Administrative Procedure Act (APA). The district court provisionally certified two classes: one consisting of researchers whose grants were terminated by form letter without grant-specific explanation (the Form Termination Class), and another whose grants were terminated specifically due to the DEI Executive Orders (the DEI Termination Class). The district court granted a preliminary injunction, ordering the reinstatement of the grants for both classes. The government appealed.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs had established Article III standing. It reversed the preliminary injunction for the Form Termination Class, concluding that the district court likely lacked jurisdiction over their APA claim because the claim was essentially contractual and thus barred by the Tucker Act. However, the Ninth Circuit affirmed the preliminary injunction for the DEI Termination Class, finding that the class was likely to succeed on its First Amendment claim because the grant terminations were based on viewpoint discrimination. The court remanded for further proceedings. View "THAKUR V. TRUMP" on Justia Law

A police officer employed by the Metropolitan Police Department experienced a data breach that exposed sensitive information of numerous employees. In response, the officer filed a putative class action in Superior Court for the District of Columbia, naming the District, certain government entities, and several private technology contractors as defendants. The complaint alleged that the defendants failed to safeguard employees’ data.During the proceedings, the plaintiff voluntarily dismissed certain contractor defendants without prejudice, leaving the government defendants and a few contractors. The Superior Court of the District of Columbia granted the District’s motion to dismiss, ruling that the Metropolitan Police Department and the Office of the Chief Technology Officer could not be sued as unincorporated government bodies, and that sovereign immunity barred the claims against the District. The plaintiff’s motion for reconsideration was denied. Subsequently, the plaintiff voluntarily dismissed without prejudice the remaining private contractor defendants and asked the Superior Court to close the case. The Superior Court closed the case, prompting the plaintiff to appeal both the dismissal of her claims against the District and the denial of reconsideration.The District of Columbia Court of Appeals reviewed the case. It held that because the plaintiff dismissed her claims against the final contractor defendants without prejudice, the trial court’s order was not final as to all parties and claims. The court explained that dismissals without prejudice do not resolve the merits and thus do not confer appellate jurisdiction, except in rare circumstances. The Court of Appeals dismissed the appeal for lack of jurisdiction, as the order below was not a final, appealable order. View "Moore v. District of Columbia" on Justia Law

A class of inmates at the Louisiana State Penitentiary alleged that the prison’s medical care was constitutionally inadequate and that the facility failed to comply with the Americans with Disabilities Act and the Rehabilitation Act. The lawsuit began in 2015, and evidence was introduced at trial in 2018. In 2021, the United States District Court for the Middle District of Louisiana issued a lengthy opinion finding systemic Eighth Amendment violations and ADA/RA noncompliance. While prison officials began making improvements ahead of a scheduled remedial trial, the district court later issued a Remedial Opinion and Order, prescribing detailed institutional changes and appointing special masters to oversee compliance.The district court’s Remedial Order required the state to bear the costs of three special masters, directed broad institutional reforms, and did not expressly adhere to the limitations imposed by the Prison Litigation Reform Act (PLRA). The court entered final judgment in favor of the plaintiffs, retaining jurisdiction only for compliance procedures. After entry of judgment, the defendants appealed. During the appeal, a panel of the United States Court of Appeals for the Fifth Circuit stayed the Remedial Order. The Fifth Circuit, sitting en banc, subsequently reviewed whether it had appellate jurisdiction and the validity of the district court’s orders.The United States Court of Appeals for the Fifth Circuit held that it had appellate jurisdiction under 28 U.S.C. § 1291 or, alternatively, § 1292(a)(1). The Fifth Circuit found that the district court’s Remedial Order violated the PLRA by failing to apply the statutory needs-narrowness-intrusiveness standard, improperly appointing multiple special masters, and requiring the state to pay their fees. The Fifth Circuit also concluded that the district court erred by disregarding ongoing improvements to prison medical care and by misapplying the standards for injunctive relief under the Eighth Amendment and the ADA/RA. The court vacated the district court’s judgment and remanded for further proceedings. View "Parker v. Hooper" on Justia Law

Three nonprofit organizations filed a nationwide class action against the United States, alleging that the federal judiciary overcharged the public for access to court records through the PACER system. They claimed the government used PACER fees not only to fund the system itself but also for unrelated expenses, contrary to the statutory limits set by the E-Government Act. The plaintiffs sought refunds for allegedly excessive fees collected between 2010 and 2018.The United States District Court for the District of Columbia oversaw extensive litigation, including class certification and an interlocutory appeal. The United States Court of Appeals for the Federal Circuit previously affirmed that the district court had subject matter jurisdiction under the Little Tucker Act and that the government had used PACER fees for unauthorized expenses. After remand, the parties reached a settlement totaling $125 million. The district court approved the settlement, finding it fair, reasonable, and adequate under Rule 23 of the Federal Rules of Civil Procedure. The court also approved attorneys’ fees, administrative costs, and incentive awards to the class representatives. An objector, Eric Isaacson, challenged the district court’s jurisdiction, the fairness of the settlement, the attorneys’ fees, and the incentive awards.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s judgment. The court held that the district court properly exercised jurisdiction under the Little Tucker Act because each PACER transaction constituted a separate claim, none exceeding the $10,000 jurisdictional limit. The appellate court found no abuse of discretion in approving the class settlement, the attorneys’ fees, or the incentive awards. The court also held that incentive awards are not categorically prohibited and are permissible if reasonable, joining the majority of federal circuits on this issue. The district court’s judgment was affirmed. View "NVLSP v. US " on Justia Law

ARcare, Inc., a nonprofit community health center receiving federal funding, suffered a data breach in early 2022 when an unauthorized third party accessed confidential patient information, including names, social security numbers, and medical treatment details. After ARcare notified affected individuals, several patients filed lawsuits alleging that ARcare failed to adequately safeguard their information as required under federal law. Plaintiffs reported fraudulent invoices and that their information was found for sale on the dark web.The actions were removed to the United States District Court for the Eastern District of Arkansas, where six class actions were consolidated. ARcare sought to invoke absolute immunity under 42 U.S.C. § 233(a) of the Federally Supported Health Centers Assistance Act (FSHCAA), which provides immunity for damages resulting from the performance of “medical, surgical, dental, or related functions.” ARcare moved to substitute the United States as defendant under the Federal Tort Claims Act, arguing the data breach arose from a “related function.” The district court denied the motion, finding that protecting patient information from cyberattacks was not sufficiently linked to the provision of health care to qualify as a “related function” under the statute.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the statutory immunity issue de novo. The court affirmed the district court’s denial of immunity, holding that the FSHCAA’s language does not extend statutory immunity to claims arising from a health center’s data security practices. The court reasoned that “related functions” must be activities closely connected to the provision of health care, and data security is not such a function. Therefore, ARcare is not entitled to substitute the United States as defendant, and the denial of statutory immunity was affirmed. View "Hale v. ARcare, Inc" on Justia Law

A group of unhoused veterans with severe disabilities and mental illnesses sued the United States Department of Veterans Affairs (VA) and the Department of Housing and Urban Development (HUD), seeking to restore the West Los Angeles VA Grounds for its intended use: housing disabled veterans. The VA had leased portions of this land to third parties—including the Regents of the University of California, Brentwood School, and Bridgeland Resources LLC—for uses that did not principally benefit veterans. Plaintiffs argued that the lack of supportive housing denied meaningful access to VA healthcare, violated the Rehabilitation Act, and placed them at serious risk of institutionalization. They also challenged VA policies that counted disability benefits as income, restricting access to supportive housing, and claimed that certain land-use agreements violated the Administrative Procedures Act (APA). Additionally, they asserted that the original 1888 Deed created a charitable trust that the VA had breached.The United States District Court for the Central District of California held a four-week bench trial, finding that the VA’s land-use leases with UCLA, Brentwood School, and Bridgeland Resources LLC were unlawful, voided these leases, and enjoined the VA from renegotiating them. The court certified a plaintiff class, ordered the VA to build supportive housing, found the VA and HUD violated the Rehabilitation Act in several respects, and determined that the VA had breached fiduciary duties under a charitable trust theory, invalidating certain leases on that basis as well.On review, the United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, vacated in part, and remanded. The Ninth Circuit held that federal courts retained jurisdiction over plaintiffs’ Rehabilitation Act claims, upheld class certification, and affirmed findings of meaningful access, Olmstead, and facial discrimination under the Rehabilitation Act against the VA. The court reversed judgment against HUD, and also reversed the charitable trust claim, finding no judicially enforceable fiduciary duties under the Leasing Act. The court vacated related injunctive relief and judgments based on the charitable trust theory, including those against UCLA, Brentwood, and Bridgeland. The injunctions were modified, allowing the VA to renegotiate leases if compliant with statutory requirements. View "Powers v. McDonough" on Justia Law