Justia Government & Administrative Law Opinion Summaries

California collects a fee from in-state hospitals and uses the revenue, along with federal Medicaid funds, to provide subsidies to California hospitals serving Medicaid beneficiaries. Out-of-state hospitals near the California border, which sometimes serve California Medicaid beneficiaries but do not pay the fee, sought access to these subsidies. They argued that their exclusion violated the dormant Commerce Clause, the Equal Protection Clause, and federal Medicaid regulations.The United States District Court for the District of Columbia rejected the out-of-state hospitals' arguments and granted summary judgment in favor of the Centers for Medicare and Medicaid Services (CMS). The hospitals appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the QAF program does not discriminate against interstate commerce because it does not tax out-of-state hospitals, and the supplemental payments are based on in-state provision of medical care. The court also found that the program does not violate the Equal Protection Clause, as California could rationally decide to target subsidies to in-state hospitals serving a disproportionate share of Medi-Cal beneficiaries. Lastly, the court concluded that the QAF program does not violate federal Medicaid regulations, as the regulation in question pertains to base payments for specific services rendered to beneficiaries, not supplemental subsidies like the QAF payments. View "Asante v. Kennedy" on Justia Law

United Water Conservation District (United) filed a lawsuit against the United States, seeking just compensation for an alleged taking under the Fifth Amendment. United claimed that the National Marine Fisheries Service (NMFS) required it to increase the amount of water bypassing its diversion dam to protect an endangered species of trout, resulting in a loss of water that United could otherwise use for beneficial purposes.The United States Court of Federal Claims dismissed United's complaint for lack of subject matter jurisdiction, determining that the claim should be evaluated as a regulatory taking. The court reasoned that United had not yet exhausted its administrative remedies by applying for and being denied an incidental-take permit under the Endangered Species Act, making the claim not ripe for adjudication.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the lower court's decision. The appellate court agreed that United's claim was regulatory in nature, as the NMFS's actions did not constitute a physical appropriation of water already diverted by United. Instead, the actions required more water to remain in the river, representing a regulatory restriction on United's use of the water. The court held that United's claim was not ripe because it had not yet obtained a final agency action by applying for and being denied an incidental-take permit. Therefore, the dismissal for lack of subject matter jurisdiction was appropriate. View "UNITED WATER CONSERVATION DISTRICT v. US " on Justia Law

Fathiree Ali, a Muslim inmate, requested the Michigan Department of Corrections to provide him with a halal diet, which is required by his religion. The prison chaplain directed him to apply for the vegan meal option, but another official rejected his application after discovering that Ali had purchased over one hundred non-halal items from the prison commissary. Ali then sued the chaplain, the special activities coordinator, the warden, and the Michigan Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Free Exercise Clause, and 42 U.S.C. § 1983.The United States District Court for the Western District of Michigan dismissed Ali’s claims against the Department of Corrections and granted summary judgment in favor of the officials. Ali appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and dismissed Ali’s appeal in part for lack of jurisdiction and affirmed the rest of the district court’s decision. The court held that RLUIPA does not authorize money-damages claims against officials sued in their official or individual capacities. The court also found that Ali’s claims for injunctive relief against the chaplain and warden were moot because they no longer had the power to adjust his meal plan after his transfer to a different prison. Additionally, the court held that Ali’s claim for injunctive relief against the special activities coordinator was moot because the coordinator no longer worked for the Department of Corrections.The court concluded that Ali did not have a cognizable claim for injunctive or declaratory relief under RLUIPA because he had alternatives to access halal meat and could reapply for the vegan meal plan. The court also found that Ali failed to state a claim against the Michigan Department of Corrections as he did not identify a policy that violated RLUIPA. Finally, the court held that the officials were entitled to qualified immunity on Ali’s Free Exercise Clause claims under § 1983. View "Ali v. Adamson" on Justia Law

The case involves two charitable organizations, Catholic Medical Mission Board, Inc. (CMMB) and Food for the Poor, Inc. (FFP), which were issued cease and desist orders and civil penalties by the Attorney General of California for allegedly making false or misleading statements in their charitable solicitations. The Attorney General found that both organizations overvalued in-kind donations and misrepresented their program efficiency ratios, leading to misleading donor solicitations.The Superior Court of Los Angeles County reviewed the case and found that the challenged statutory provisions, sections 12591.1(b) and 12599.6(f)(2) of the Government Code, were unconstitutional under the First Amendment as they constituted prior restraints on speech. The court vacated the civil penalties and issued permanent injunctions against the Attorney General, preventing the enforcement of these provisions. The court also reformed section 12591.1(b) to exclude violations of section 12599.6 from the Attorney General’s cease and desist authority.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the trial court’s constitutional rulings but vacated the permanent injunctions, stating that the trial court abused its discretion by granting them without requiring the plaintiffs to plead and prove entitlement to such relief. The appellate court remanded the case to allow the plaintiffs to amend their complaints to seek injunctive relief and to prove they are entitled to it. The court also affirmed the trial court’s reformation of section 12591.1(b) and vacated the postjudgment orders awarding attorney fees, directing the trial court to reconsider the fees in light of the appellate court’s rulings. View "Catholic Medical Mission Board, Inc. v. Bonta" on Justia Law

Praxis Packaging Solutions, operating a manufacturing facility, applied for a tax exemption for its manufacturing equipment under Michigan law. The Township of Byron's assessor denied the application, stating the equipment did not meet the statutory definition of eligible manufacturing personal property (EMPP). The denial notice informed Praxis of its right to appeal to the March Board of Review but did not provide specific deadlines or meeting dates. Praxis's agents contacted the assessor for appeal details but were not informed of the deadlines. Praxis submitted an appeal letter after the Board had adjourned, and the Board did not consider the appeal.The Michigan Tax Tribunal dismissed Praxis's petition for lack of jurisdiction, as Praxis had not first appealed to the Board. The Court of Appeals reversed, holding that the Township's notice did not meet statutory requirements and deprived Praxis of due process, thus vesting the Tribunal with jurisdiction.The Michigan Supreme Court reviewed the case and held that the Township's notice did not violate due process. The Court found that the notice, combined with the separate notice of assessment, provided sufficient information about the appeal process. The Court emphasized that due process requires notice reasonably calculated to inform the taxpayer and provide an opportunity to be heard. Since Praxis received actual notice of the Board's meeting dates and the appeal process, the Court concluded that there was no due process violation.The Supreme Court reversed the Court of Appeals judgment and reinstated the Tax Tribunal's dismissal of Praxis's petition for lack of jurisdiction, as Praxis failed to timely protest the exemption denial before the Board. View "Sixarp LLC v. Township Of Byron" on Justia Law

The case involves the interpretation of the Gun Control Act of 1968 (GCA) in relation to weapon parts kits and unfinished frames or receivers. The GCA mandates that those involved in the import, manufacture, or sale of firearms must obtain federal licenses, keep sales records, conduct background checks, and mark their products with serial numbers. The Act defines a "firearm" to include any weapon that can expel a projectile by explosive action and the frame or receiver of such a weapon. With the rise of weapon parts kits that can be assembled into functional firearms, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) adopted a rule in 2022 to include these kits under the GCA's regulations.The District Court vacated the ATF's rule, agreeing with the plaintiffs that the GCA does not cover weapon parts kits or unfinished frames or receivers. The Fifth Circuit affirmed this decision, holding that the GCA's definition of "firearm" does not extend to weapon parts kits or unfinished frames and receivers, regardless of their completeness or ease of assembly.The Supreme Court of the United States reviewed the case and reversed the Fifth Circuit's decision. The Court held that the ATF's rule is not facially inconsistent with the GCA. The Court found that some weapon parts kits, like Polymer80's "Buy Build Shoot" kit, qualify as "weapons" under the GCA because they can be readily converted into functional firearms. Additionally, the Court held that the GCA's definition of "frame or receiver" includes some partially complete frames or receivers that can be easily finished using common tools. The Court concluded that the ATF has the authority to regulate these items under the GCA. The case was remanded for further proceedings consistent with this opinion. View "Bondi v. Vanderstok" on Justia Law

At the onset of the COVID-19 pandemic, the Governor of Kentucky issued orders prohibiting mass gatherings, including religious services, and closing non-life-sustaining organizations, which included religious organizations. Maryville Baptist Church held an Easter service in defiance of these orders, leading to a lawsuit against the Governor, alleging violations of the First and Fourteenth Amendments.The United States District Court for the Western District of Kentucky initially declined to issue a preliminary injunction. However, the Sixth Circuit Court of Appeals issued a partial stay, allowing outdoor worship. Subsequently, the district court granted a preliminary injunction, permitting both indoor and outdoor worship. The Governor later allowed places of worship to reopen, and the Kentucky General Assembly limited the Governor's authority to issue similar orders in the future. The underlying action was dismissed as moot, and the Church sought attorney’s fees, which the district court denied, ruling that the Church did not prevail.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court referenced the U.S. Supreme Court's decision in Lackey v. Stinnie, which held that a party who receives a preliminary injunction but whose case becomes moot before a final judgment does not qualify as a prevailing party under 42 U.S.C. § 1988. Applying this precedent, the Sixth Circuit affirmed the district court's denial of attorney’s fees, concluding that the Church's preliminary injunction did not constitute enduring judicial relief that materially altered the legal relationship between the parties. View "Maryville Baptist Church v. Beshear" on Justia Law

A fourteen-year-old boy, Tanner Smith, was vaccinated against COVID-19 at his school clinic without his or his mother Emily Happel's consent. The school clinic, operated in partnership with Old North State Medical Society (ONSMS), administered the vaccine despite lacking the required parental consent. Plaintiffs, Smith and Happel, sued the Guilford County Board of Education and ONSMS for battery and violations of their state constitutional rights.The Superior Court of Guilford County dismissed the case, agreeing with the defendants that the federal Public Readiness and Emergency Preparedness (PREP) Act preempted the plaintiffs' state law claims, granting them immunity. The Court of Appeals affirmed this decision, holding that the PREP Act's broad immunity shielded the defendants from liability for all of the plaintiffs' claims.The Supreme Court of North Carolina reviewed the case and held that the PREP Act's immunity only covers tort injuries and does not bar state constitutional claims. The court concluded that the PREP Act does not preempt claims brought under the state constitution, specifically those related to the right to control a child's upbringing and the right to bodily integrity. The court affirmed the dismissal of the battery claim but reversed the dismissal of the state constitutional claims and remanded the case for further proceedings. View "Happel v. Guilford Cnty. Bd. of Education" on Justia Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

Volcano Telephone Company, a rural telephone service provider, receives subsidies from the California High-Cost Fund-A (A-Fund) administered by the Public Utilities Commission (PUC). Volcano Vision, Inc., an affiliate, uses Volcano Telephone’s broadband-capable facilities, subsidized by the A-Fund, to deliver broadband services without contributing to the underlying costs. The PUC considered Volcano Vision’s net revenues in setting Volcano Telephone’s A-Fund subsidy and future rates. The PUC also required Volcano Telephone to submit broadband service quality metrics related to Volcano Vision’s services.The PUC issued Decision No. 23-02-008, calculating Volcano Telephone’s A-Fund subsidy and approving rates for 2023. Volcano Telephone and Volcano Vision challenged this decision, arguing that the PUC’s implementation of broadband imputation constituted an unconstitutional taking and conflicted with federal law. They also contended that the order to submit broadband service quality metrics was outside the scope of the proceedings and the PUC’s jurisdiction. The PUC denied rehearing and modified the decision to clarify the reporting requirements.The California Court of Appeal, Third Appellate District, reviewed the case. The court rejected the petitioners’ claims, affirming Decision Nos. 23-02-008 and 23-08-051. The court held that the PUC’s implementation of broadband imputation did not constitute an unconstitutional taking, as the A-Fund program is voluntary, and the petitioners failed to demonstrate that the rate of return was confiscatory. The court also found that the order to submit broadband service quality metrics was within the scope of the proceedings and the PUC’s jurisdiction. The court concluded that the PUC’s decisions were supported by substantial evidence and did not violate any constitutional rights. View "Volcano Telephone Co. v. Public Utilities Commission" on Justia Law