Justia Government & Administrative Law Opinion Summaries

Hyatt sued the Franchise Tax Board of California in Nevada state court for alleged torts committed during a tax audit. The Supreme Court affirmed the Nevada Supreme Court, holding that the Full Faith and Credit Clause did not prohibit Nevada from applying its own immunity law. On remand, the Nevada Supreme Court declined to apply a cap on tort liability applicable to Nevada state agencies. The Supreme Court reversed but was divided on whether to overrule Nevada v. Hall, which held that the Constitution does not bar suits brought by an individual against a state in the courts of another state. On remand, the Nevada Supreme Court instructed the trial court to enter damages in accordance with Nevada’s statutory cap.The Supreme Court then overruled Nevada v. Hall. States retain sovereign immunity from private suits brought in courts of other states. The Constitution assumes that the states retain sovereign immunity except as otherwise provided and fundamentally adjusts the states’ relationship with each other. Article III abrogated certain aspects of the states’ traditional immunity by providing a neutral federal forum in which the states agreed to be amenable to suits brought by other states; in ratifying the Constitution, the states similarly surrendered some of their immunity, consenting to suits brought against them by the United States in federal courts. The Eleventh Amendment confirms that the Constitution was not meant to “rais[e] up” any suits against the states that were “anomalous and unheard of when the Constitution was adopted,” and implies that the Constitution was understood, in light of its history and structure, to preserve the states’ traditional immunity from private suits. State sovereign immunity in another state’s courts is integral to the structure of the Constitution. The states “are no longer fully independent nations free to disregard each other’s sovereignty.” View "Franchise Tax Board of California v. Hyatt" on Justia Law

Lopez-Aguilar went to the Indianapolis Marion County Courthouse for a hearing on a misdemeanor complaint charging him with driving without a license. Officers of the Sheriff’s Department informed him that an ICE officer had come to the courthouse earlier that day looking for him. He alleges that Sergeant Davis took him into custody. Later that day, Lopez-Aguilar appeared in traffic court and resolved his misdemeanor charge with no sentence of incarceration. Sergeant Davis nevertheless took Lopez-Aguilar into custody. He was transferred to ICE the next day. Neither federal nor state authorities charged Lopez-Aguilar with a crime; he did not appear before a judicial officer. ICE subsequently released him on his own recognizance. An unspecified “immigration case” against Lopez-Aguilar was pending when he sued county officials under 42 U.S.C. 1983. Following discovery, the parties settled the case. The district court approved the Stipulated Judgment over the objection of the federal government and denied Indiana’s motion to intervene to appeal. The Seventh Circuit reversed. The state’s motion to intervene was timely and fulfilled the necessary conditions for intervention of right. The district court was without jurisdiction to enter prospective injunctive relief. The Stipulated Judgment interferes directly and substantially with the use of state police power to cooperate with the federal government in the enforcement of immigration laws. View "Lopez-Aguilar v. Indiana" on Justia Law

Flat Creek filed suit seeking declaratory and injunctive relief, alleging that the Federal Motor Carrier Safety Administration had unfairly targeted it for compliance reviews and used an unsound methodology in doing so. The district court concluded that it lacked subject matter jurisdiction. The Eleventh Circuit affirmed the district court's dismissal of the complaint, but held that Flat Creek failed to establish the requisite standing to sue under Article III. In this case, Flat Creek has shown neither concreteness nor imminence. View "Flat Creek Transportation, LLC v. Federal Motor Carrier Safety Administration" on Justia Law

In this suit brought by the Commonwealth of Massachusetts seeking to enjoin the enforcement of two federal Interim Final Rules (IFRs), the First Circuit vacated the district court's determination that Massachusetts lacked standing to challenge the IFRs, holding that the Commonwealth had standing to challenge the rules.The IFRs at issue in this case were promulgated by the United States Departments of Health and Human Services, Labor, and the Treasury and permitted employers with religious or moral objections to contraception to obtain exemptions from providing health insurance coverage to employees and their dependents for FDA-approved contraceptive care. The district court determined that the Commonwealth failed to establish standing because it had not set forth specific facts establishing that it would likely suffer future injury from the Departments' conduct. After the Commonwealth filed its appeal, the Departments issued final rules superseding the IFRs. The First Circuit held (1) the Commonwealth's substantive challenges to the federal regulations were not moot, but its procedural challenge to the IFRs was mooted by the promulgation of the final rules; and (2) the Commonwealth had Article III standing to challenge the Departments' actions. View "Commonwealth of Massachusetts v. Department of Health & Human Services" on Justia Law

The Supreme Court affirmed the order of the circuit court affirming the determination of the Board of Equalization and Review that Petitioners Murray Energy Corporation and Consolidation Coal Company's coal interests were properly valued and assessed by Defendants, holding that the circuit court properly concluded that the method of valuing coal properties violated neither the statutory requirement of assessment at "true and actual value" nor the constitutional equality requirements of the West Virginia Constitution and the equal protection provisions of the United States and West Virginia Constitutions.Specifically, the Court held (1) the methodology of valuing Petitioners' coal properties for ad valorem tax valuation purposes, as set forth in West Virginia Code of State Rules 110-1I-1 et seq., does not violate the requirement set forth in W. Va. Code 11-6K-1(a) that natural resources property be assessed based upon its "true and actual value"; and (2) the valuation methodology contained in the Code of State Rules does not violate the equality provision of W. Va. Const. art. X, 1 or the equal protection provisions of the United States and West Virginia Constitutions. View "Murray Energy Corp. v. Steager" on Justia Law

In a case brought in the Pennsylvania Supreme Court's original jurisdiction, Petitioner Sands Bethworks Gaming, LLC, challenged a recent amendment to Pennsylvania gaming law in which casinos paid a supplemental assessment on slot-machine revenue, and the funds are then distributed primarily to underperforming slot-machine facilities to be used for marketing and capital development. Sands alleged that the amendment violated the Pennsylvania Constitution’s requirement of uniform taxation, its mandate that all enactments have a public purpose, and its rule against special legislation. Sands also claimed the scheme violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment to the federal Constitution. The Supreme Court concluded the amendments were indeed unconstitutional, and the offending parts could be severed from the rest of the statute. Any assessment monies paid to the Commonwealth pursuant to the amended gaming law were ordered to be refunded. View "Sands Bethworks Gaming v. PA Dept of Revenue et al" on Justia Law

In 2004, the Pennsylvania General Assembly transferred regulatory authority over Philadelphia taxicabs to the Philadelphia Parking Authority (“Authority”) through Act 94. The Act also created a budget submission process for the Authority to follow, and prescribed a formula that the Authority uses to ascertain assessments imposed upon Philadelphia taxicabs. In 2013, the Commonwealth Court found certain portions of Act 94 to be unconstitutional. The General Assembly then enacted Act 64 to cure the constitutional shortcomings identified by the Commonwealth Court. Partial rights taxicab owners in Philadelphia challenged the new scheme on constitutional grounds. The Commonwealth Court granted relief, finding that Subsection 5707(c) of the Parking Authorities Law, 53 Pa.C.S. 5707(c), violated the substantive due process rights of partial rights taxicab owners. Furthermore, the Commonwealth Court found that the budget submission process prescribed in 53 Pa.C.S. sections 5707(a) and 5710 constituted an unconstitutional delegation of legislative power. Upon review, the Pennsylvania Supreme Court concluded the Commonwealth Court erred in both respects: (1) subsection 5707(c) did not impair the substantive due process rights of partial rights taxicab owners; (2) subsections 5707(a) and 5710 did not amount to unconstitutional delegations of legislative power. View "Germantown Cab Co., et al. v. P.P.A." on Justia Law

Plaintiffs appealed the district court's grant of summary judgment to the FCC and the Government, in an action alleging that part of the Telephone Consumer Protection Act of 1991 (TCPA) contravenes the Free Speech Clause of the First Amendment. In relevant part, the Act prohibits calls to cell phones by use of an automated dialing system or an artificial or prerecorded voice, subject to three statutory exemptions. Specifically, plaintiffs alleged that one of the statutory exemptions to the automated call ban — created by a 2015 TCPA amendment — is facially unconstitutional under the Free Speech Clause.Although the Fourth Circuit agreed with the district court that strict scrutiny review applied in this case, it held that the debt collection exemption fails to satisfy strict scrutiny, constitutes an unconstitutional content-based restriction on speech, and therefore violates the Free Speech Clause. The court concluded that the flawed exemption could be severed from the automatic call ban. Accordingly, the court vacated and remanded. View "American Association of Political Consultants, Inc. v. FCC" on Justia Law

This case arose when a member of the House of Representatives asked the House-appointed Chaplain, Father Patrick J. Conroy, to invite Daniel Barker—a former Christian minister turned atheist—to serve as guest chaplain and deliver a secular invocation. After Conroy denied the request, Barker filed suit alleging that Conroy unconstitutionally excluded him from the guest chaplain program because he is an atheist.The DC Circuit affirmed the district court's dismissal of Barker's Establishment Clause claim. The court held that, although Barker had Article III standing to challenge his exclusion from the program, he failed to state a claim upon which relief could be granted. The court held that Marsh v. Chambers, 463 U.S. 783 (1983), and Town of Greece v. Galloway, 572 U.S. 565, 570 (2014), leave no doubt that the Supreme Court understands our nation's longstanding legislative-prayer tradition as one that, because of its "unique history," can be both religious and consistent with the Establishment Clause. The court noted that, although the Supreme Court has warned against discriminating among religions or tolerating a pattern of prayers that proselytize or disparage certain faiths or beliefs, it has never suggested that legislatures must allow secular as well as religious prayer. Therefore, in the sui generis context of legislative prayer, the court held that the House does not violate the Establishment Clause by limiting its opening prayer to religious prayer. View "Barker v. Conroy" on Justia Law

The United States challenged California's enactment of three laws expressly designed to protect its residents from federal immigration enforcement: AB 450, which requires employers to alert employees before federal immigration inspections; AB 103, which imposes inspection requirements on facilities that house civil immigration detainees; and SB 54, which limits the cooperation between state and local law enforcement and federal immigration authorities.The Ninth Circuit held that the district court did not abuse its discretion when it concluded that AB 450's employee-notice provisions neither burden the federal government nor conflict with federal activities, and that any obstruction caused by SB 54 is consistent with California's prerogatives under the Tenth Amendment and the anticommandeering rule. Therefore, the panel affirmed the district court's denial of a preliminary injunction as to these laws.The panel also affirmed the district court's denial of a preliminary injunction as to those provisions of AB 103 that duplicate inspection requirements otherwise mandated under California law. However, the panel held that one subsection of AB 103—codified at California Government Code section 12532(b)(1)(C)—discriminates against and impermissibly burdens the federal government, and so is unlawful under the doctrine of intergovernmental immunity. Therefore, the panel reversed the preliminary injunction order as to this part and remanded for further proceedings. View "United States v. California" on Justia Law