Justia Government & Administrative Law Opinion Summaries

Two non-domiciliary companies, S&H Independent Premium Brands East, LLC, and S&H Independent Premium Brands West, LLC, import and distribute European alcoholic beverages in the United States. They hold certificates of compliance under Massachusetts General Laws Chapter 138, Section 18B, allowing them to sell alcoholic beverages to licensed wholesalers in Massachusetts. In 2019, an Austrian malt beverage producer, Stiegl Getränke & Service GmbH & Co. KG, terminated its distribution agreement with S&H without prior notice and entered into a new agreement with another distributor, Win-It-Too, Inc.S&H filed a petition with the Alcoholic Beverages Control Commission (ABCC), alleging that Stiegl violated Massachusetts General Laws Chapter 138, Section 25E, which prohibits suppliers from refusing to sell to any licensed wholesaler without good cause. The ABCC dismissed the petition, stating that Section 25E protections apply only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. S&H then sought judicial review in the Superior Court, which upheld the ABCC's decision, agreeing that Section 25E protections do not extend to Section 18B certificate holders.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The Court held that the term "any licensed wholesaler" in Section 25E refers only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. The Court also concluded that this interpretation does not violate the dormant commerce clause of the United States Constitution, as Section 18B certificate holders and Section 18 licensed wholesalers serve different roles in the regulatory framework. Therefore, the ABCC's decision to dismiss S&H's petition was upheld. View "S&H Independent Premium Brands East, LLC v. Alcoholic Beverages Control Commission" on Justia Law

This case involves a dispute over the sale of surplus state property owned by the Idaho Transportation Department (ITD). The property, located at 3311 West State Street in Boise, was declared surplus after a flood rendered its largest building unusable. The Idaho Department of Administration (DOA) initiated a bidding process, and the petitioners, a group of business entities, submitted the highest bid. Despite negotiating a purchase and sale agreement, the DOA did not finalize the sale due to legislative actions that revoked its authority to dispose of the property and transferred control back to the ITD Board.The petitioners filed an original action in the Idaho Supreme Court seeking writs of prohibition and mandate. They argued that the legislative provisions revoking the DOA's authority were unconstitutional, violating the single-subject rule of the Idaho Constitution. They sought a declaratory judgment to invalidate these provisions and compel the DOA to complete the sale. The Idaho House of Representatives and its Speaker intervened, and the State Board of Examiners disclaimed further participation, having fulfilled its statutory duties.The Idaho Supreme Court held that the petitioners lacked standing to bring the action. The court found that while the petitioners demonstrated a distinct and palpable injury from the halted sale, they failed to show that a favorable decision would redress their injury. The court noted that the petitioners did not have a legally enforceable right to purchase the property, as the DOA had discretion in concluding the sale. Additionally, the court determined that the petitioners did not meet the criteria for relaxed standing, as other parties, such as the DOA and ITD, could potentially bring the constitutional claim. Consequently, the court dismissed the petition for writs of prohibition and mandate. View "Hawkins Companies, LLC v. State" on Justia Law

The case involves several states suing the President of the United States, the Secretary of Education, and the U.S. Department of Education to prevent the implementation of a plan to forgive approximately $475 billion in federal student loan debt. The plan, known as SAVE, significantly alters the existing income-contingent repayment (ICR) plan by lowering payment amounts, often to $0 per month, and forgiving principal balances much sooner than previous plans.The United States District Court for the Eastern District of Missouri granted a preliminary injunction in part, finding that Missouri had standing through its state instrumentality, MOHELA, which faced certain irreparable harm. The court concluded that the states had a fair chance of success on the merits, particularly that loan forgiveness under SAVE was not statutorily authorized and violated the separation of powers under the major-questions doctrine. However, the court only enjoined the ultimate forgiveness of loans, not the payment-threshold provisions or the nonaccrual of interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the district court that Missouri had standing. The court found that the states demonstrated a fair chance of success on the merits, noting that the SAVE plan's scope was even larger than a previously contested loan-cancellation program. The court also found that the Government's actions had rendered the district court's injunction largely ineffective. Balancing the equities, the court decided to grant in part and deny in part the states' motion for an injunction pending appeal, prohibiting the use of the hybrid rule to circumvent the district court's injunction. The injunction will remain in effect until further order of the court or the Supreme Court of the United States. View "State of Missouri v. Biden" on Justia Law

The plaintiffs challenged the constitutionality of North Carolina’s sex offender registration statute, arguing that it violated the Ex Post Facto Clause of the Constitution by retroactively imposing new punishments for crimes committed in the past. The statute requires offenders to report personal information to law enforcement and restricts where they can live, work, and visit. The plaintiffs, including two nonprofit organizations and two individuals, sought to bar the retroactive application of certain amendments to the statute.The United States District Court for the Middle District of North Carolina held a bench trial and found that the statute was nonpunitive and thus did not violate the Ex Post Facto Clause. The court concluded that the legislature intended to create a civil, nonpunitive scheme and that the plaintiffs failed to show by the clearest proof that the statute’s effects were punitive.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court agreed that the legislature intended to enact a civil, nonpunitive scheme aimed at protecting public safety. The court also found that the statute was rationally connected to this nonpunitive purpose and was not excessive in relation to its goal. Although the statute imposed significant burdens on registrants, the court concluded that these burdens did not amount to punishment. The court held that the plaintiffs did not provide the clearest proof that the statute’s effects were so punitive as to override the legislature’s intent.Therefore, the Fourth Circuit affirmed the district court’s judgment, upholding the constitutionality of North Carolina’s sex offender registration statute under the Ex Post Facto Clause. View "National Assoc. For Rational Sexual Offense Laws v. Stein" on Justia Law

In 2017, Special Counsel Robert S. Mueller III began investigating Russian interference in the 2016 presidential election, during which Giorgi Rtskhiladze testified before a grand jury. When the Department of Justice (DOJ) released a redacted version of Mueller’s report, it included information that Rtskhiladze claimed was inaccurate and damaging to his reputation. Rtskhiladze sued for both equitable and monetary relief and sought a copy of his grand jury testimony transcript.The United States District Court for the District of Columbia ruled that Rtskhiladze lacked standing for his equitable claims, failed to state a claim for damages, and was not entitled to obtain a copy of the transcript. The court found that Rtskhiladze had abandoned his separate damages claim against DOJ and Mueller personally and forfeited arguments about this claim on appeal.The United States Court of Appeals for the District of Columbia Circuit held that Rtskhiladze has standing to bring all his claims and remanded the equitable claims for further consideration. The court agreed with the district court that Rtskhiladze failed to state a claim for damages under the Privacy Act, as he did not allege "intentional or willful" conduct by DOJ. The court also upheld the district court’s decision to deny Rtskhiladze’s request to obtain a copy of his grand jury testimony transcript, emphasizing the government’s interest in maintaining grand jury secrecy and preventing witness intimidation.In summary, the appellate court reversed the district court’s dismissal of Rtskhiladze’s equitable claims for lack of standing, affirmed the dismissal of his damages claim for failure to state a claim, and upheld the denial of his request to obtain a copy of his grand jury transcript. View "Rtskhiladze v. Mueller" on Justia Law

The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) issued a final rule reclassifying pistols equipped with stabilizing braces as short-barreled rifles under the National Firearms Act (NFA) and the Gun Control Act (GCA). This reclassification subjects these weapons to stringent regulations. The plaintiffs, including a stabilizing-brace manufacturer, a firearm manufacturer, a gun association, an individual owner, and twenty-five states, challenged the rule, arguing it exceeded the ATF’s statutory authority and was arbitrary and capricious. The district court denied the plaintiffs' motion for a preliminary injunction, leading to this appeal.The United States District Court for the District of North Dakota initially reviewed the case and denied the plaintiffs' request for a preliminary injunction. The court concluded that the plaintiffs did not demonstrate a substantial likelihood of success on the merits of their claims, which included arguments that the rule exceeded the ATF’s statutory authority and was arbitrary and capricious. The plaintiffs then appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the plaintiffs were likely to succeed on the merits of their arbitrary-and-capricious challenge. The court held that the ATF’s rule was arbitrary and capricious because it lacked clear metrics for determining when a stabilizing brace provides sufficient surface area to shoulder a weapon, and the multifactor test used by the ATF was internally inconsistent and inadequately explained. Additionally, the court found that the accompanying slideshows, which classified certain weapons as short-barreled rifles without explanation, further demonstrated the arbitrary nature of the rule. Consequently, the Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded the case for reconsideration consistent with its opinion. View "Firearms Regulatory Accountability Coalition, Inc. v. Garland" on Justia Law

Robert William Doelz was convicted of possession of methamphetamine with intent to distribute. In 2019, the Kansas Supreme Court reversed his conviction, finding that his Fourth Amendment rights were violated due to a warrantless search, and the evidence obtained should have been suppressed. On remand, the State dropped the charge and did not pursue a retrial. Subsequently, Doelz sought compensation for his wrongful conviction under K.S.A. 2020 Supp. 60-5004, which requires proving actual innocence among other criteria.The Shawnee District Court denied both parties' motions for summary judgment, interpreting K.S.A. 2023 Supp. 60-5004(c)(1)(C) to require a claimant to prove that their innocence resulted in the reversal of their conviction, dismissal of charges, or a not guilty verdict upon retrial. The court found that Doelz's conviction was reversed due to a Fourth Amendment violation, not because he did not commit the crime. Since there was no evidence explaining why the charges were dismissed, a material fact remained unresolved. At a bench trial, Doelz testified to his innocence, but the court granted the State's motion for judgment as a matter of law, finding that Doelz failed to prove the charges were dismissed due to his innocence.The Kansas Supreme Court affirmed the district court's decision. The court held that K.S.A. 2023 Supp. 60-5004(c)(1)(C) requires a claimant to prove actual innocence and that this innocence led to the reversal, dismissal, or acquittal. The court found that the legislative intent behind the statute was to compensate only those who are factually innocent. Since Doelz did not provide evidence that the charges were dismissed because of his innocence, he did not meet the statutory requirements for compensation. View "In the Matter of the Wrongful Conviction of Doelz" on Justia Law

The plaintiffs, Indian nationals residing in the U.S. on nonimmigrant work visas and their children, sought to adjust their status to permanent residents. They challenged policies by the U.S. Citizenship and Immigration Services (USCIS) and the U.S. Department of State (DOS) that determine the eligibility of derivative beneficiaries, claiming these policies violate the Equal Protection Clause and the Administrative Procedure Act (APA).The U.S. District Court for the District of Oregon dismissed the plaintiffs' complaint for failure to state a claim, allowing them to amend their complaint. Instead of amending, the plaintiffs appealed. During the appeal, the Supreme Court decided Patel v. Garland, which held that federal courts lack jurisdiction to review factual findings in discretionary-relief proceedings under 8 U.S.C. § 1255. The government argued that this ruling meant the courts also lacked jurisdiction over the plaintiffs' claims.The United States Court of Appeals for the Ninth Circuit vacated the district court's dismissal and remanded the case, holding that the district court lacked jurisdiction over most of the plaintiffs' claims because they were not ripe. The Ninth Circuit concluded that 8 U.S.C. § 1252(a)(2)(B)(i) does not strip federal district courts of jurisdiction to hear collateral challenges to generally applicable policies and procedures. However, the claims were not ripe because the plaintiffs had not applied for adjustment of status, and USCIS had not denied their applications based on the challenged policies. For the one plaintiff who did apply and was denied, the court held that her claims must be channeled through a petition for review from a final order of removal, as per §§ 1252(a)(2)(B)(i) and (D). The Ninth Circuit's interpretation aligns with other circuits, maintaining that general policy challenges are not precluded by § 1252(a)(2)(B)(i). View "NAGENDRA NAKKA V. USCIS" on Justia Law

Amy Romero was arrested for driving while under the influence of alcohol (DWUI) after being found stuck in a snowbank. Officer George Phillips of the Rawlins Police Department noticed the vehicle and, upon investigation, detected a strong odor of alcohol from Ms. Romero. During the interaction, Ms. Romero admitted to driving the vehicle and exhibited signs of intoxication. Officer Phillips placed her in the back of his patrol car to deescalate a potentially violent situation with her husband, Joseph Romero, who was also present and behaving aggressively.The Office of Administrative Hearings (OAH) upheld the suspension of Ms. Romero’s driver’s license, concluding that Officer Phillips had reasonable suspicion to detain her for a DWUI investigation. The OAH found that the officer’s actions, including placing Ms. Romero in the patrol car and transporting her to a dry environment for field sobriety tests, were justified based on the totality of the circumstances, including the strong odor of alcohol, her admission of driving, and the need to manage her husband’s aggressive behavior.The Wyoming Supreme Court reviewed the case and affirmed the OAH’s decision. The Court held that Officer Phillips’ detention of Ms. Romero in the back of the patrol car did not constitute an unlawful arrest but was a reasonable investigative detention supported by substantial evidence. The Court found that the officer’s actions were necessary to ensure safety and were within the scope of a lawful investigative detention. The Court concluded that the OAH’s findings were supported by substantial evidence and that the detention was in accordance with constitutional protections. The decision to uphold the suspension of Ms. Romero’s driver’s license was affirmed. View "Romero v. State of Wyoming Ex Rel., Wyoming Department of Transportation" on Justia Law

The plaintiffs, Miriam Lowell and Seth Healey, challenged the Vermont Department for Children and Families (DCF) after being investigated for child abuse and neglect. DCF substantiated the allegations and notified the plaintiffs, who then requested an administrative review. The review process was delayed, and the plaintiffs filed a federal lawsuit claiming the process violated their due process rights. The federal court denied their injunction request, and the plaintiffs later filed a similar complaint in state court, seeking declaratory and injunctive relief, and mandamus under Vermont Rule of Civil Procedure 75.The Superior Court, Washington Unit, Civil Division, dismissed the complaint, assuming the plaintiffs had a protected liberty interest but finding the administrative review process constitutionally sufficient. The court noted that the plaintiffs' claims of potential procedural violations were speculative and not reviewable. The plaintiffs appealed, arguing that the administrative review process did not provide adequate due process protections.The Vermont Supreme Court dismissed Lowell's claims as moot because the administrative reviewer overturned the substantiation against her, providing her with no further relief. For Healey, the court assumed a protected liberty interest but found the administrative review process constitutionally adequate under the Mathews v. Eldridge test. The court noted that the process provided sufficient notice and an opportunity to be heard, with a neutral arbiter and the ability to present evidence. The court emphasized the importance of DCF's interest in protecting children and the availability of a prompt post-deprivation hearing before the Human Services Board, which offers more extensive procedural protections. The court affirmed the trial court's dismissal of Healey's complaint, concluding that the administrative review process met due process requirements. View "Lowell v. Department for Children and Families" on Justia Law