Justia Government & Administrative Law Opinion Summaries

In 2016, voters in Donegal Township, Washington County, Pennsylvania, decided to increase the number of members on the township’s board of supervisors from three to five. Subsequently, in 2020, the voters opted to reduce the number back to three. This led to a legal dispute involving Richard Martin, Jr., Richard Fidler, and Tammy Iams, who were elected to the five-member board but faced shortened terms due to the reduction.The Court of Common Pleas of Washington County initially dismissed the action brought by Martin, Fidler, and Iams, who challenged the constitutionality of Section 402(e) of the Second Class Township Code. The Commonwealth Court partially reversed this decision, ruling that Section 402(e) was unconstitutional as applied to Martin and Fidler, as it effectively removed them from office before their terms expired, contrary to Article VI, Section 7 of the Pennsylvania Constitution.The Supreme Court of Pennsylvania reviewed the case and focused on whether Section 402(e) was unconstitutionally applied. The Court held that Section 402(e) did not result in the removal of Martin and Fidler from office but rather modified their terms due to the reduction in the number of supervisors. The Court emphasized that Article VI, Section 7 of the Pennsylvania Constitution, which provides the exclusive method for removing elected officials, was not applicable because the statute did not involve removal but rather a lawful modification of legislative office terms.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision, upholding the application of Section 402(e) and concluding that it did not violate the Pennsylvania Constitution. The Court found that the reduction in the number of supervisors and the subsequent election for the new three-member board were constitutionally permissible actions by the legislature. View "Martin v. Donegal Township" on Justia Law

The plaintiffs, parents of minor children, challenged a public act that eliminated the religious exemption from vaccination requirements for school enrollment. They argued that the act violated their constitutional rights to free exercise of religion, equal protection, and a free public education, as well as their statutory rights under Connecticut law. The defendants, state and municipal officials, moved to dismiss the case on the grounds of sovereign immunity.The trial court denied the defendants' motions to dismiss, concluding that the plaintiffs' constitutional claims satisfied the substantial claim exception to sovereign immunity, and their statutory claim under Connecticut law satisfied the statutory waiver exception. The defendants appealed this decision.The Connecticut Supreme Court reviewed the case and determined that the trial court must assess the legal sufficiency of the plaintiffs' allegations to determine whether they have asserted a substantial claim of a constitutional violation. The court concluded that the plaintiffs' constitutional claims failed as a matter of law. The act was deemed a neutral law of general applicability, rationally related to the state's interest in protecting public health. The court also found that the act did not violate the plaintiffs' right to a free public education, as it imposed a reasonable vaccination requirement.However, the court agreed with the trial court that the plaintiffs' statutory free exercise claim under Connecticut law satisfied the statutory waiver exception to sovereign immunity. The court found that the scope of the waiver extended to free exercise challenges to the enforcement of legislation and that applying the statute to the public act did not violate any constitutional principles.The Connecticut Supreme Court reversed the trial court's decision in part, directing the dismissal of the constitutional claims, but affirmed the decision regarding the statutory claim, allowing it to proceed. View "Spillane v. Lamont" on Justia Law

A plaintiff filed a lawsuit against the State, arguing that the statutory definition of "sustained yield" under AS 16.05.255(k) violates the Alaska Constitution’s sustained yield provision. The plaintiff contended that the legislature lacked the authority to define sustained yield and that the statutory definition contradicted the constitutional provision. The plaintiff sought declaratory and injunctive relief, requesting the court to declare the statute unconstitutional and to enjoin the State from enforcing it.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, reviewed the case. The court denied the State’s motion to dismiss, which was based on res judicata and collateral estoppel, determining that the issues raised were not precluded by prior litigation. The court then granted summary judgment in favor of the State, concluding that the statutory definition of sustained yield in AS 16.05.255(k) complies with the Alaska Constitution.The Supreme Court of the State of Alaska reviewed the case on appeal. The court analyzed the plain meaning of the constitutional and statutory provisions, the intent of the framers of the Alaska Constitution, and relevant precedent. The court found that the legislature had the authority to define sustained yield in statute and that the statutory definition was consistent with the broad principle of sustained yield as intended by the framers. The court emphasized that the Constitution allows for legislative discretion in establishing management priorities for natural resources.The Supreme Court of Alaska affirmed the superior court’s judgment, holding that AS 16.05.255(k)’s definition of sustained yield does not violate the Alaska Constitution and that the statute has a plainly legitimate sweep. View "West v. State of Alaska" on Justia Law

A Nevada limited liability company, Mass Land Acquisition, LLC, challenged the use of eminent domain by Sierra Pacific Power Company, d/b/a NV Energy, to take an easement across its property for a natural gas pipeline. NV Energy sought immediate occupancy of the property, while Mass Land argued that such a taking by a private entity violated the Nevada Constitution and requested a jury determination on whether the taking was for a public use.The First Judicial District Court of Nevada denied Mass Land's motion to dismiss and granted NV Energy's motion for immediate occupancy. The court concluded that NV Energy, as a regulated public utility, was exercising delegated eminent domain powers and acting as the government, not as a private party. The court also found that the taking was for a natural gas pipeline, a statutorily recognized public use, and thus did not require a jury determination on public use before granting occupancy.The Supreme Court of Nevada reviewed the case and denied Mass Land's petition for a writ of mandamus or prohibition. The court held that the Nevada Constitution's prohibition on transferring property taken by eminent domain to another private party did not apply to NV Energy's taking for a natural gas pipeline, as it was a public use. The court also determined that there were no genuine issues of material fact requiring a jury determination on whether the taking was actually for a public use. The court concluded that NV Energy's actions were lawful and consistent with the statutory and constitutional provisions governing eminent domain in Nevada. View "MASS LAND ACQUISITION, LLC VS. DISTRICT COURT" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

The case involves a dispute between a taxpayers' association and a water district over the imposition of groundwater replenishment charges. The taxpayers' association alleged that the water district's charges violated constitutional provisions and unfairly benefited large agricultural businesses. The association sought a writ of mandate to stop the collection of these charges and to vacate the resolutions imposing them. They also claimed conversion, civil conspiracy, aiding and abetting, and violations of the Unfair Competition Law (UCL) against the water district's board members, general manager, and consulting firms.The Superior Court of Riverside County denied the defendants' anti-SLAPP motion, which sought to strike several causes of action on the grounds that they arose from protected activities. The court found that the public interest exemption to the anti-SLAPP statute applied. Additionally, the court sustained the defendants' demurrer to the first amended petition and complaint, finding the claims time-barred under the validation statutes. The court also awarded over $180,000 in attorney's fees to the plaintiffs, deeming the anti-SLAPP motion frivolous.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the public interest exemption did not apply because the relief sought could only be provided by the water district, not the individual defendants. The court found that the anti-SLAPP motion should have been granted for most causes of action, except for conversion and the writ of mandate against the general manager. Consequently, the fee award was reversed. The court also affirmed the demurrer ruling, as the claims against the individual defendants were not legally sufficient. The case was remanded for further proceedings consistent with these findings. View "Howard Jarvis Taxpayers Assn. v. Powell" on Justia Law

Adam Richardson, a citizen and taxpayer, petitioned the Supreme Court of Florida for writs of quo warranto and mandamus, alleging that the Governor, Attorney General, and Secretary of the Florida Agency for Health Care Administration (AHCA) violated section 104.31, Florida Statutes, by advocating against a proposed constitutional amendment (Amendment 4) related to abortion rights. Richardson claimed that their actions, including statements on an AHCA webpage and social media, as well as participation in a public call and opinion piece, unlawfully interfered with the vote on Amendment 4.The lower courts did not review this case as it was directly brought to the Supreme Court of Florida. Richardson argued that the respondents' actions violated a statute limiting political activities of state officers and employees, which he believed should be enforced through extraordinary writs.The Supreme Court of Florida denied the petition. The court held that the writ of quo warranto is traditionally used to test the right of a person to hold an office or exercise a state-derived power, not to compel criminal prosecution or enable private enforcement of a criminal statute. The court found that Richardson's grievances were more about the merits of the respondents' actions rather than their authority to act. Additionally, the court denied the writ of mandamus, stating that Richardson did not establish a clear legal right or an indisputable legal duty on the part of the respondents, nor did he show that there was no other adequate remedy available. The court concluded that no further relief was required to complete the exercise of its jurisdiction and denied the petition without permitting a rehearing. View "Richardson v. Secretary, Florida Agency for Health Care Administration" on Justia Law

The case involves a challenge to Montana House Bill 702 (HB 702), which prohibits discrimination based on vaccination status. Plaintiffs, including health care providers and individuals with compromised immune systems, argued that HB 702 is preempted by the Americans with Disabilities Act (ADA) and the Occupational Health and Safety Act (OSH Act) and violates the Equal Protection Clause of the Fourteenth Amendment. They sought to invalidate HB 702 in all health care settings, claiming it prevents employers from knowing employees' vaccination status, thus hindering ADA-required accommodations and OSH Act compliance.The United States District Court for the District of Montana ruled in favor of the plaintiffs, holding that HB 702 is preempted by the ADA and the OSH Act and violates the Equal Protection Clause. The court issued a permanent injunction against the enforcement of HB 702 in health care settings, reasoning that the law conflicts with federal requirements for reasonable accommodations and workplace safety.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision and vacated the injunction. The Ninth Circuit held that neither the ADA nor the OSH Act facially preempts HB 702 in health care settings. The court found that the plaintiffs did not demonstrate a genuine conflict between HB 702 and the ADA or OSH Act in any specific case, much less in all health care settings. The court also held that HB 702 does not violate the Equal Protection Clause, as the classification and differential treatment of facilities could rationally reflect Montana's interest in balancing personal privacy and public health.The Ninth Circuit reserved judgment on whether the ADA and the OSH Act could preempt HB 702 on a narrower, as-applied basis in future cases. The court deemed moot the portion of the district court's order related to interim CMS regulations, as those regulations have been rescinded. The court concluded that HB 702 is not facially invalid under the ADA, OSH Act, or Equal Protection Clause and vacated the district court's injunction in full. View "MONTANA MEDICAL ASSOCIATION V. KNUDSEN" on Justia Law

A group called Moms for Liberty, along with several individual members, filed a lawsuit against Brevard Public Schools and members of the Brevard County School Board. The plaintiffs claimed that their speech was unconstitutionally restricted at school board meetings. They argued that the Board's policies prohibiting "abusive," "personally directed," and "obscene" speech were unconstitutional. The plaintiffs sought declaratory and injunctive relief, as well as nominal damages.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Board. The district court concluded that the plaintiffs lacked standing because they could not show an actual or imminent injury. It also held that the Board's policies did not objectively chill the plaintiffs' protected speech. Despite finding no standing, the district court went on to rule that the Board's policies were constitutional.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The Eleventh Circuit found that the plaintiffs had standing to seek both retrospective and prospective relief. The court held that the Board's policy on "abusive" speech was unconstitutional because it was viewpoint-based and prohibited offensive speech. The policy on "personally directed" speech was also found to be unreasonable and inconsistently enforced, making it unconstitutional. Lastly, the court ruled that the prohibition on "obscene" speech was unreasonably applied to restrict protected speech, particularly when it involved reading from books available in school libraries. The case was remanded for further proceedings consistent with the Eleventh Circuit's opinion. View "Moms for Liberty v. Brevard Public Schools" on Justia Law

Plaintiffs, including Free Speech Coalition, Inc. and others, sought to prevent Utah officials from enforcing a law requiring age verification for online pornography. They argued that the law violated the First Amendment and other constitutional rights. The law allows private parties to sue commercial entities that fail to verify users' ages. Plaintiffs claimed this law imposed unconstitutional restrictions on free speech and sought declaratory and injunctive relief against the Attorney General of Utah and the Commissioner of the Utah Department of Public Safety.The United States District Court for the District of Utah dismissed the case, ruling that the defendants were entitled to Eleventh Amendment immunity. The court found that the defendants did not enforce or give effect to the law, thus the Ex parte Young exception to sovereign immunity did not apply. The district court also noted that the Commissioner’s oversight of a mobile driver's license program did not constitute enforcement of the law, as the program did not yet provide for online age verification.The United States Court of Appeals for the Tenth Circuit affirmed the district court's dismissal. The appellate court agreed that neither the Attorney General nor the Commissioner enforced or gave effect to the law. The court held that the Ex parte Young exception did not apply because the law placed enforcement authority with private individuals, not state officials. The court also found that the Commissioner’s management of the mobile driver's license program was too attenuated to constitute enforcement of the law. Consequently, the court affirmed the dismissal of the plaintiffs' complaint based on Eleventh Amendment immunity. View "Free Speech Coalition v. Anderson" on Justia Law