Justia Government & Administrative Law Opinion Summaries

Tennessee and sixteen other states challenged a regulation by the Equal Employment Opportunity Commission (EEOC) under the Pregnant Workers Fairness Act, which mandates reasonable accommodations for pregnancy-related conditions, including abortion. The states argued that the regulation unlawfully required them to accommodate employees seeking abortions, conflicting with their policies. They sought an injunction and a declaratory judgment against the rule, claiming it was arbitrary, exceeded EEOC's authority, violated the First Amendment and federalism principles, and was unconstitutional under Article II.The United States District Court for the Eastern District of Arkansas dismissed the case, ruling that the states lacked standing as they did not demonstrate an imminent injury or that the alleged injuries were redressable. The court found the risk of enforcement speculative and compliance costs not directly traceable to the rule. The court also dismissed the states' motion for a preliminary injunction as moot and for failing to show irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that the states had standing as they were the direct objects of the EEOC's regulation, which imposed new obligations on them. The court found that the states were injured by the regulatory burden itself and that setting aside the rule would remedy this injury. The court concluded that the states' need to comply with the rule constituted an injury in fact, caused by the EEOC's action, and redressable by a favorable judicial decision. The case was remanded for further proceedings without addressing the merits of the claims. View "State of Tennessee v. EEOC" on Justia Law

A transgender woman, Darlene Griffith, filed a civil rights lawsuit regarding her pretrial confinement at the El Paso County Jail in Colorado. She alleged that the jail's policies, which assigned housing based on genitalia and denied her access to female clothing and products, violated her constitutional rights and the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court dismissed her complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), leading to this appeal.The United States District Court for the District of Colorado dismissed Ms. Griffith’s complaint, concluding that she failed to state a plausible claim for relief. The court applied rational-basis review to her Equal Protection claim, finding that transgender individuals are not a protected class under existing precedent. The court also dismissed her ADA and Rehabilitation Act claims for lack of subject matter jurisdiction, as she did not properly name the county as a defendant according to state law requirements.The United States Court of Appeals for the Tenth Circuit reviewed the case and concluded that remand was required for some of Ms. Griffith’s claims. The court reversed and remanded for further proceedings on her Fourteenth Amendment Equal Protection claim against Sheriff Elder in his official capacity, her Fourth and Fourteenth Amendment cross-gender search claims against Sheriff Elder in his official capacity, and her Fourth Amendment abusive search claim against Deputy Mustapick. The court vacated the district court’s order dismissing Ms. Griffith’s ADA and Rehabilitation Act claims under Rule 12(b)(6) because those claims were dismissed without prejudice for lack of subject matter jurisdiction under Rule 12(b)(1), and that ruling was unchallenged on appeal. The court otherwise affirmed the district court’s dismissal of the remaining claims. View "Griffith v. El Paso County, Colorado" on Justia Law

A resident of Alaska filed a lawsuit challenging amendments to the State’s predator control program. The resident claimed that after the changes were implemented, she observed a noticeable decrease in the brown bear population at Katmai National Park, where she frequently visited to view bears. She argued that the Board of Game violated its constitutional and statutory duties by not providing adequate notice and opportunities for public input before adopting the changes, which expanded the program to target bears.The Superior Court of Alaska, Third Judicial District, dismissed the complaint, concluding that the resident lacked standing and was not entitled to a declaratory judgment on the validity of the regulatory change. The court also awarded attorney’s fees to the Board of Game and the Commissioner of the Department of Fish & Game.The Supreme Court of the State of Alaska reviewed the case and held that the resident had standing because she demonstrated an injury to her interest in viewing bears at Katmai National Park, which was sufficient to show standing. The court also concluded that she was entitled to a declaratory judgment on the validity of the regulation. The Supreme Court reversed the dismissal of her complaint, vacated the associated award of attorney’s fees, and remanded the case for further proceedings. View "Bittner v. State of Alaska" on Justia Law

Debbie Mayfield, a former member of the Florida House of Representatives and Florida Senate, sought to run in a special election for Senate District 19 after the incumbent announced his resignation. Mayfield submitted the necessary paperwork to qualify for the ballot, but the Secretary of State and Director of the Division of Elections refused to place her on the ballot, citing a constitutional provision on term limits.The Circuit Court did not review the case. Mayfield directly petitioned the Supreme Court of Florida for writs of mandamus and quo warranto, arguing that the Secretary misinterpreted his authority and failed to fulfill his statutory duty.The Supreme Court of Florida reviewed the case and granted Mayfield's petition for mandamus relief. The court held that Mayfield had a clear legal right to appear on the ballot, as she had met all statutory requirements for qualification. The court found that the Secretary's role in reviewing candidate qualifications is ministerial and does not include the authority to assess a candidate's constitutional eligibility. The court also rejected the Secretary's interpretation of the term-limits provision, concluding that Mayfield's break in service meant she had not served more than eight consecutive years in the Senate. The court ordered the Secretary to place Mayfield on the ballot by a specified deadline and denied the petition for quo warranto as moot. View "Mayfield v. Secretary, Florida Department of State" on Justia Law

Several members of the public requested records from the Seattle Police Department (SPD) regarding officers who attended the January 6, 2021, rally in Washington, DC. The officers involved filed a lawsuit to prevent the release of their identities, arguing that their identities should be exempt from disclosure based on statutory and constitutional privacy rights. They sought a preliminary injunction to prevent the release of their identities within those public records.The King County Superior Court denied the officers' motion for a preliminary injunction, determining that the officers failed to show that the information in the public records was likely exempt from disclosure. The court also denied the officers' motion to proceed under pseudonyms. The officers appealed, and the Court of Appeals reversed the denial of the preliminary injunction, concluding that the First Amendment prohibited the disclosure of the officers' identities. The Court of Appeals did not evaluate whether the disclosure would violate the officers' statutory right to privacy under the Public Records Act (PRA).The Supreme Court of the State of Washington reviewed the case and held that the officers did not demonstrate a likelihood of success on the merits that their identities were exempt based on either a statutory or constitutional right to privacy. The court concluded that the officers did not have a privacy interest in their identities as public employees who attended a highly publicized event. The court also held that the officers did not show a need to litigate under pseudonyms. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "John Does v. Seattle Police Dep't" on Justia Law

In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law

Joseph Rivera's driver's license was permanently revoked by New York authorities after he was convicted of three alcohol-related driving offenses between 2000 and 2010. Rivera moved to Alaska in 2011 but did not apply for an Alaska driver's license until 2021. His application was denied by the Alaska Department of Motor Vehicles (DMV) because his license was still revoked in New York. Rivera sought reinstatement of his driving privileges in New York, but his requests were denied. He then requested an administrative hearing with the Alaska DMV, which upheld the denial of his application.Rivera appealed to the Superior Court of the State of Alaska, Third Judicial District, arguing that the DMV misapplied Alaska's licensing statutes and that the statutes conflicted. The superior court affirmed the DMV's decision, rejecting Rivera's arguments.The Supreme Court of the State of Alaska reviewed the case and held that Alaska's driver’s license statutes do not conflict. The court found that the statutes operate in harmony, with the Compact providing a framework for considering out-of-state driving records and Alaska's statutes imposing additional requirements. Specifically, Alaska Statute 28.15.031(b)(1) prevents the DMV from issuing a license to anyone whose driving privileges are revoked in any jurisdiction, including out-of-state revocations. The court concluded that the DMV properly applied this statute in denying Rivera's application.The court also addressed Rivera's arguments regarding equal protection and manifest injustice, finding them unpersuasive. The court noted that Rivera had not exhausted all available appeals in New York and that the DMV's decision did not result in manifest injustice. Consequently, the Supreme Court of the State of Alaska affirmed the superior court's judgment and upheld the DMV's decision to deny Rivera's application for a driver's license. View "Rivera v. State" on Justia Law

Tim Daniels, a commercial fisherman in Florida, challenged the constitutionality of regulations by Florida’s Fish and Wildlife Conservation Commission (FWC) that restrict where and how Florida-registered vessels can harvest Florida pompano in federal waters. Daniels argued that federal law preempts state regulations affecting fishing in federal waters and that Florida’s regulations violate the Equal Protection Clause by only restricting Florida-registered vessels.The United States District Court for the Southern District of Florida granted summary judgment for the FWC, concluding that Florida’s regulations do not violate the Privileges and Immunities Clause, the Supremacy Clause, the Commerce Clause, or the Equal Protection Clause. The court also determined that Daniels lacked standing to sue.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that Daniels has standing to sue because he faces a credible threat of prosecution under Florida’s regulations, which affects his commercial fishing activities. The court found that Daniels’s injury is directly traceable to Florida’s regulations and can be redressed by a favorable judicial decision.On the merits, the Eleventh Circuit held that the Magnuson-Stevens Fishery Conservation and Management Act does not preempt Florida’s regulations. The court reasoned that the Act allows states to regulate fishing vessels registered under their laws in federal waters when there is no federal fishery management plan or regulations in place. The court also held that Florida’s regulations do not violate the Equal Protection Clause because they are rationally related to the legitimate governmental purpose of conserving and managing pompano stock, and the regulations only apply to Florida-registered vessels, which are within the state’s jurisdiction.The Eleventh Circuit affirmed the District Court’s decision, upholding Florida’s pompano regulations. View "Daniels v. Executive Director of the Florida Fish and Wildlife Conservation Commission" on Justia Law

Rhonda Fleming, an inmate at Federal Correctional Institution Tallahassee (FCIT), filed a pro se lawsuit against Warden Erica Strong and the United States, alleging Eighth Amendment violations due to her exposure to mold, asbestos, and COVID-19, which she claimed caused severe health issues. Fleming sought injunctive relief and damages under Bivens and the Federal Tort Claims Act (FTCA). She alleged that despite her complaints, the prison officials, including Warden Strong, failed to address the hazardous conditions, leading to her contracting COVID-19 twice and requiring hospitalization.The United States District Court for the Northern District of Florida partially granted and partially denied the defendants' motion to dismiss. The magistrate judge recommended dismissing most of Fleming's claims, including all claims against Strong, citing that Bivens did not provide a remedy for her Eighth Amendment claim. However, the district court disagreed, finding that Fleming's Eighth Amendment claim was similar to a previously recognized Bivens claim and allowed it to proceed. The district court did not address the issue of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court had to determine whether it had jurisdiction to hear an interlocutory appeal from the district court's order recognizing a Bivens cause of action. The Eleventh Circuit joined four other circuits in holding that the collateral-order doctrine does not extend to Bivens-extension orders that do not address qualified immunity. The court emphasized that qualified immunity adequately protects government officials from the burdens of litigation and that separation-of-powers concerns with Bivens extensions do not justify immediate appeal. Consequently, the Eleventh Circuit dismissed the appeal for lack of jurisdiction. View "Fleming v. FCI Tallahassee Warden" on Justia Law

The case involves a proposed charter amendment in Baltimore City, known as the Baby Bonus Amendment, which would mandate a one-time payment of at least $1,000 to every eligible city resident upon the birth or adoption of a child. The Maryland Child Alliance, Inc. sponsored the petition for this amendment, which was certified by the Baltimore City Board of Elections for inclusion on the ballot for the November 2024 Presidential General Election.The Mayor and City Council of Baltimore, along with other city officials, filed a lawsuit in the Circuit Court for Baltimore City against the Baltimore City Board of Elections and the State Board of Elections, seeking judicial review, a writ of mandamus, declaratory judgment, and an injunction to prevent the Baby Bonus Amendment from being placed on the ballot. The circuit court granted the City’s motion for summary judgment, declaring the Baby Bonus Amendment unconstitutional as it violated Article XI-A, § 3 of the Maryland Constitution by removing meaningful discretion from the City over an area within its legislative purview and being legislative in nature rather than proper charter material.The Supreme Court of Maryland reviewed the case and affirmed the circuit court’s decision. The Court held that the Baby Bonus Amendment did not concern the form or structure of government and encroached upon the City’s police or general welfare powers, thus violating Article XI-A, § 3 of the Maryland Constitution. The Court also declined to sever the mandatory payment provision from the amendment, concluding that the dominant purpose of the amendment would not be achieved without the $1,000 payment provision, which abrogated the City’s law-making authority in violation of the Constitution of Maryland. View "Baltimore City Board of Elections v. Mayor and City Council of Baltimore" on Justia Law