Justia Government & Administrative Law Opinion Summaries

The case revolves around the legality of the Emergency Management Act (the Act) in Minnesota, which allows the Governor to declare a peacetime emergency in response to a pandemic. The appellants, led by Drake Snell, challenged the Act, arguing that it did not authorize the Governor to declare a peacetime emergency in response to the COVID-19 pandemic and that it violated the nondelegation doctrine.Previously, the district court had dismissed Snell's case, concluding that the Act was a constitutional delegation of power to the Governor. The court of appeals affirmed this decision, stating that the Act granted the Governor the authority to declare a peacetime emergency in response to the COVID-19 pandemic. The court of appeals declined to consider Snell's argument that the Act violated the nondelegation doctrine, holding that it was not within the scope of remand.The Supreme Court of Minnesota affirmed the decision of the court of appeals. The court concluded that the Act does authorize a governor to declare a peacetime emergency in response to a public health crisis such as a pandemic. Furthermore, the court found that Governor Walz was authorized under the Act to declare a peacetime emergency in response to the COVID-19 pandemic. Lastly, the court rejected Snell's contention that the Act violates the nondelegation doctrine, stating that the Act does not represent an unconstitutional delegation of legislative authority. The court noted that the Act places durational limits on the powers and subjects them to termination by the Legislature, thus providing a check on the Governor's powers. View "Procaccini vs. Walz" on Justia Law

The case involves the Alaska Trappers Association and the National Trappers Association (collectively, the Trappers) who challenged a city ordinance enacted by the City of Valdez. The ordinance regulated animal trapping within the city limits, barring trapping in certain areas for the purpose of protecting public safety and domesticated animals. The Trappers argued that the ordinance was invalid and unconstitutional, asserting that it was preempted by state law and violated the Alaska Constitution.The Superior Court of the State of Alaska, Third Judicial District, Valdez, granted summary judgment in favor of the City of Valdez. The court concluded that the legislature's delegation of authority to the Board of Game was limited and did not grant the Board exclusive control of trapping. The court also determined that the ordinance did not directly contradict state regulations.Upon appeal, the Supreme Court of the State of Alaska affirmed the lower court's decision. The Supreme Court held that the ordinance was not prohibited by the Alaska Constitution or the legislature’s delegation of authority over fish and game to the Board. The court concluded that the ordinance was not impliedly prohibited by state law, as it was enacted pursuant to Valdez's authority to regulate land use and public safety, and was not substantially irreconcilable with the State's authority to regulate the conservation, development, or utilization of game. View "Alaska Trappers Association, Inc. v. City of Valdez" on Justia Law

The case involves Maria Esparraguera, a career appointee in the Senior Executive Service (SES), who was removed from her position by the Department of the Army. Esparraguera claimed that her constitutional due process rights were violated by the Army. The district court dismissed her suit, stating that she failed to show that the removal implicated a property interest protected by the Due Process Clause.Previously, the district court had dismissed Esparraguera’s due process claim, finding that she had no constitutionally protected property interest in her SES status. The court did not address whether the process Esparraguera received (or the absence thereof) complied with the Due Process Clause. Esparraguera appealed this decision.The United States Court of Appeals for the District of Columbia Circuit reversed the district court's decision. The appellate court found that Esparraguera had a protected property interest in her SES status. The court reasoned that the statutory and regulatory provisions applicable to her case gave Esparraguera a property interest in her SES status. The court also concluded that the government was required to provide her, at a minimum, some form of meaningful notice and an opportunity to be heard before removing her from the SES. The case was remanded back to the district court for further proceedings. View "Esparraguera v. Department of the Army" on Justia Law

The case revolves around two Senate Bills—2780 and 3064—passed by the Mississippi Legislature in 2022. Senate Bill 2780 established the Independent Schools Infrastructure Grant Program (ISIGP), which allowed independent schools to apply for reimbursable grants for infrastructure projects funded by the Coronavirus State Fiscal Recovery Funds under the federal American Rescue Plan Act (ARPA). Senate Bill 3064 allocated $10 million from the Coronavirus State Fiscal Recovery Fund to ISIGP. Parents for Public Schools (PPS), a nonprofit organization advocating for public schools, filed a complaint alleging that ISIGP violated the Mississippi Constitution by appropriating public funds to private schools. PPS sought injunctive and declaratory relief, asserting associational standing on behalf of its members.The Chancery Court of Hinds County found that PPS had established associational standing. It also found that Senate Bills 2780 and 3064 violated the Mississippi Constitution by appropriating public funds to private schools. The court denied a motion to intervene by the Midsouth Association of Independent Schools (MAIS), which sought to challenge the constitutionality of the relevant section of the Mississippi Constitution under the First and Fourteenth Amendments.The Supreme Court of Mississippi, however, found that PPS lacked standing to bring the lawsuit. The court determined that PPS failed to demonstrate an adverse impact different from that of the general public. The court noted that the funds at issue were federal, not state, funds earmarked for specific infrastructure needs, and were not commingled with state funds. The court also found that PPS's challenge to general government spending was too attenuated to bestow standing. As a result, the court vacated the judgment of the Hinds County Chancery Court and rendered judgment dismissing PPS's complaint. View "Midsouth Association of Independent Schools v. Parents for Public Schools" on Justia Law

The case involves the City of San José and the Howard Jarvis Taxpayers Association (HJTA). The city had a significant unfunded liability in its pension plans for city employees. To address this shortfall, the city council adopted a resolution authorizing the issuance and sale of bonds, provided they result in savings for the city. The HJTA argued that this action violated the constitutional debt limitation, which prohibits cities from incurring any indebtedness or liability exceeding the income and revenue provided for a given year without the assent of two-thirds of the voters.The trial court upheld the city's actions, ruling that the bond issuance falls under the obligation imposed by law exception to the debt limitation. The HJTA appealed this decision, arguing that the city's actions violate the constitutional debt limitation and lack statutory authority.The Court of Appeal of the State of California, Sixth Appellate District, affirmed the judgment, but for different reasons than the trial court. The appellate court concluded that the city has not incurred any indebtedness or liability exceeding its annual income and revenue because the city's actions do not trigger the constitutional debt limitation. The court also found that the city has the authority under state law to issue the bonds. View "City of San Jose v. Howard Jarvis Taxpayers Assn." on Justia Law

The case involves the Pennsylvania Public Utility Commission (PUC) and the City of Lancaster, Borough of Carlisle, and Borough of Columbia (collectively referred to as the Municipalities). The dispute centers around Section 59.18 of the PUC’s regulations, which gives natural gas distribution companies (NGDCs) the authority to determine the location of gas meters in historic districts. The Municipalities argued that this regulation violates Article II, Section 1 of the Pennsylvania Constitution, which vests legislative power in the General Assembly, not in private entities like NGDCs.The Commonwealth Court agreed with the Municipalities, concluding that Section 59.18 unlawfully delegates legislative authority to NGDCs without providing adequate standards to guide their decisions. The court therefore declared Section 59.18 unenforceable.The PUC appealed this decision to the Supreme Court of Pennsylvania. The PUC argued that Section 59.18 does not delegate legislative power to NGDCs, but rather is a regulatory act under the PUC’s administrative authority. The PUC also contended that the Commonwealth Court failed to consider the safety issues related to meter placement, which is the primary concern of the regulation.The Supreme Court of Pennsylvania reversed the decision of the Commonwealth Court. The court found that the General Assembly never enacted a statute giving the PUC legislative authority to determine the location of gas meters in historic districts. Therefore, the PUC could not have unlawfully delegated this authority to NGDCs. The court concluded that the Municipalities' disagreement with the PUC's regulation does not amount to a constitutional violation. The case was remanded to the Commonwealth Court for further proceedings. View "City of Lancaster v. PUC" on Justia Law

The case involves a dispute over the adjusted Medicaid reimbursement rates for for-profit residential health care facilities in New York. The New York State Department of Health and its Commissioner, in response to a legislative mandate, eliminated a component known as the "residual equity reimbursement factor" from the computation formula used to set these rates. This change was part of a broader effort to reduce Medicaid costs in the state. The petitioners, 116 for-profit nursing homes, challenged this adjustment, arguing that it was retroactively applied and violated their rights under the Public Health Law and the Equal Protection Clause.The Supreme Court partially granted the petitioners' motion for a preliminary injunction against enforcement of the clause pending a final determination of the proceeding. It also partially granted the respondents' motion for summary judgment, dismissing the petitioners' claims that the adjusted rates were not "reasonable and adequate to meet costs" under the Public Health Law and violated their equal protection rights. However, the court found that the adjusted rates were improperly applied retroactively. The Appellate Division affirmed the Supreme Court's decision.The New York Court of Appeals, in its review, held that the Department of Health did not violate the legislature's intent when it announced the recalculated rates for services provided on or after April 2, 2020. The court found that the legislature clearly expressed its intent for the elimination clause to be applied without delay, and that the initial implementing ratemaking was not subject to the usual 60-day advance notice requirement. The court also rejected the petitioners' claims that the adjusted rates were not "reasonable and adequate to meet costs" and violated their equal protection rights. The court modified the order of the Appellate Division in accordance with its opinion and, as so modified, affirmed it. View "In re Aaron Manor Rehabilitation & Nursing Ctr., LLC v Zucker" on Justia Law

The case involves Jennifer Root Bannon, who sued six law enforcement officers and the City of Boston on behalf of her brother's estate. Her brother, Juston Root, was fatally shot by the officers after a series of events that began with him pointing a gun at a hospital security guard and a responding police officer, leading the officers on a high-speed chase, and disregarding police instructions to drop his weapon. Bannon claimed that the officers used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the defendants.The United States Court of Appeals for the First Circuit agreed with the district court's conclusion that the officers acted reasonably under the circumstances during the fatal shooting and did not violate the Fourth Amendment. The court also held that the officers were entitled to qualified immunity and affirmed the grant of summary judgment on Bannon's other claims. The court found that no reasonable jury could conclude that the officers acted unreasonably in employing deadly force against Root in violation of the Fourth Amendment. The court also independently concluded that the officers were entitled to summary judgment on Bannon's § 1983 and MCRA claims based on qualified immunity. View "Bannon v. Godin" on Justia Law

The case involves Salt Lake County's challenge to the constitutionality of the Aircraft Valuation Law, which provides a preferred method for determining the fair market value of aircraft for tax purposes. The County argued that the application of the law to Delta Air Lines' aircraft resulted in an assessment below fair market value, violating the Utah Constitution. The County also contended that the law, on its face, violated the Utah Constitution by divesting the Utah State Tax Commission of its power to assess airline property.The Utah State Tax Commission had previously upheld the 2017 assessment of Delta's property, which was calculated according to the Aircraft Valuation Law. The Commission found that the County did not provide clear and convincing evidence that the legislature's preferred method of valuation did not reasonably reflect fair market value.The Supreme Court of the State of Utah rejected the County's arguments. The court held that the County failed to fully utilize the statutory safety valve, which allows the Commission to use an alternative valuation method if the preferred method does not reasonably reflect fair market value. The court also rejected the County's facial challenge to the Aircraft Valuation Law, concluding that the County did not show that the law prohibits the legislature from prescribing a preferred method for valuing aircraft. Therefore, the court affirmed the Commission's decision. View "Salt Lake Co v. Tax Commission" on Justia Law

The case involves four appellants who are parole-eligible inmates serving life sentences in the Kentucky Department of Corrections. They were denied any further opportunity at parole for the remainder of their sentences by the Kentucky Parole Board. The appellants challenged the Board's authority to issue a "serve-out," arguing that it violates the constitutional separation of powers.The Franklin Circuit Court concluded that the Board was within its statutory authority to issue a serve-out on a life sentence and granted summary judgment to the Board. The Kentucky Court of Appeals affirmed the lower court's decision, reasoning that the legislature had not prohibited the Board from authorizing serve-outs on life sentences.The Supreme Court of Kentucky affirmed the decisions of the lower courts. The court held that the Board has the power to issue a serve-out to an inmate serving a life sentence. The court reasoned that while the current statutory scheme may not explicitly authorize the Board to grant serve-outs, the relevant legislative and administrative history indicates that the legislature has condoned the Board’s use of this power. The court also held that the Board's power to issue a serve-out does not violate the constitutional separation of powers. The court concluded that a serve-out is authorized by the legislature and is not constitutionally impermissible. View "CONN V. KENTUCKY PAROLE BOARD" on Justia Law