Justia Government & Administrative Law Opinion Summaries

Several individuals whose livelihoods depended on interacting with spinner dolphins challenged a federal regulation that restricted human proximity to these dolphins. The regulation, known as the Approach Rule, was issued by the National Marine Fisheries Service under the authority of the Marine Mammal Protection Act. The plaintiffs included a psychotherapist who used dolphin encounters in therapy, a boat captain who operated dolphin swim tours, and a dolphin guide and photographer. They argued that the regulation was unconstitutional because it was signed and promulgated by an official who, they claimed, was not properly appointed under the Appointments Clause of the U.S. Constitution.The United States District Court for the District of Maryland reviewed the case after the plaintiffs filed suit seeking to invalidate the regulation and enjoin its enforcement. During the litigation, Dr. Richard Spinrad, the Senate-confirmed NOAA Administrator and a principal officer, ratified the regulation, affirming that he independently evaluated and approved it. The district court found that this ratification cured any potential Appointments Clause defect and granted summary judgment in favor of the government. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that, under established principles of agency law, a principal officer’s ratification of a regulation can cure any constitutional defect arising from its initial promulgation by a non-principal officer. The court found that Dr. Spinrad’s ratification was valid and not impermissibly retroactive, as it did not impose new liabilities for past conduct but merely confirmed the regulation’s validity from the time of its original publication. Accordingly, the Fourth Circuit affirmed the district court’s dismissal of the suit. View "Wille v. Lutnik" on Justia Law

An Oregon nonprofit organization, whose board members are guided by sincerely held religious beliefs, challenged a state law requiring most employers to provide insurance coverage for abortion and contraceptive services. The organization’s governing documents and public statements reflect a commitment to traditional Judeo-Christian ethics, including opposition to abortion based on religious grounds. Although the law contains exemptions for certain religious employers, the organization does not qualify for any of these exceptions, a point not disputed by the state. The organization sought relief, arguing that being compelled to provide such coverage violates its rights under the First and Fourteenth Amendments.The United States District Court for the District of Oregon denied the organization’s request for a preliminary injunction and dismissed its complaint. The district court found there was doubt as to whether the organization’s opposition to abortion was genuinely religious in nature. It further concluded that the law was neutral and generally applicable, subject only to rational basis review, which it satisfied.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal and vacated the denial of a preliminary injunction. The Ninth Circuit held that the organization’s beliefs are religious and sincerely held, and that the district court erred by not accepting these allegations as true at the motion to dismiss stage. The appellate court remanded the case for the district court to reconsider, in light of the Supreme Court’s decision in Catholic Charities Bureau, Inc. v. Wisconsin Labor & Industry Review Commission, whether the selective denial of a religious exemption to the organization violates the First Amendment. The Ninth Circuit expressed no opinion on the ultimate constitutional question, leaving it for the district court to address in the first instance. View "OREGON RIGHT TO LIFE V. STOLFI" on Justia Law

A candidate for Congress, who holds both a medical degree and a law degree but is not licensed to practice medicine, referred to himself as “Dr. Gonzalez” and a “physician” during his campaign. The Texas Medical Board (TMB) received a complaint alleging that these statements constituted the unlicensed practice of medicine and improper use of professional titles. After an investigation and hearing, TMB determined that the candidate had violated the Medical Practice Act and the Healing Art Identification Act, issuing a cease-and-desist order prohibiting him from using the titles “doctor,” “physician,” or “Dr.” without clarifying his lack of a medical license. The candidate challenged the order, arguing both statutory and constitutional grounds, including that the statutes violated his free speech rights.The Travis County District Court dismissed all of the candidate’s claims for lack of jurisdiction. The Court of Appeals for the Third District of Texas affirmed the dismissal of most claims, holding that the redundant-remedies doctrine barred his ultra vires and as-applied constitutional claims because he could have sought relief through the Administrative Procedure Act (APA). However, the appellate court remanded his facial constitutional challenge to the district court for further proceedings.The Supreme Court of Texas reviewed the case and held that the redundant-remedies doctrine did not bar the candidate’s ultra vires and as-applied constitutional claims, because the relief he sought—declaratory and injunctive relief against future enforcement—went beyond what the APA could provide. The court affirmed the dismissal of his substantial-evidence claim for lack of jurisdiction, as there was no statutory basis for judicial review outside the APA. The Supreme Court of Texas reversed in part, affirmed in part, and remanded for further proceedings on the facial constitutional, as-applied constitutional, and ultra vires claims. View "GONZALEZ v. TEXAS MEDICAL BOARD" on Justia Law

Several businesses involved in the cultivation, distribution, and sale of hemp products in Wyoming and elsewhere challenged a Wyoming statute, Senate Enrolled Act 24 (SEA 24), which significantly altered the state’s regulation of hemp. SEA 24 narrowed the definition of hemp to exclude synthetic substances and expanded the definition of THC to include both delta-9 and delta-8 THC, requiring that the combined concentration not exceed 0.3%. The law also added both naturally occurring and synthetic delta-8 THC to Wyoming’s Schedule I controlled substances, making it unlawful to manufacture, deliver, or possess hemp products exceeding the new THC limits or containing synthetic substances, even if such products are legal under federal law.After SEA 24 was enacted, the plaintiffs filed a preenforcement action in the United States District Court for the District of Wyoming, seeking declaratory and injunctive relief. They argued that SEA 24 was preempted by the federal 2018 Farm Bill, violated the Dormant Commerce Clause, constituted an unconstitutional regulatory taking, and was void for vagueness. The plaintiffs also sought a temporary restraining order or preliminary injunction to prevent the law from taking effect. The district court denied the motion for preliminary relief and subsequently dismissed the complaint for failure to state a claim, finding that most defendants were protected by Eleventh Amendment immunity and that the remaining claims lacked legal merit.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s dismissal. The court held that the plaintiffs lacked a substantial federal right to support their preemption claim, failed to demonstrate a Dormant Commerce Clause violation, did not establish a regulatory taking of their commercial personal property, and did not show that SEA 24 was unconstitutionally vague. The court also dismissed the appeal of the denial of preliminary relief as moot due to the dismissal of the complaint. View "Green Room v. State of Wyoming" on Justia Law

A woman with a lifelong hearing impairment obtained a commercial driver’s license (CDL) in New Jersey after receiving a federal exemption from the standard hearing requirement. This exemption allowed her to drive commercial vehicles in interstate commerce but specifically prohibited her from operating passenger vehicles or school buses. Despite this, she was mistakenly issued state endorsements permitting her to drive such vehicles and worked as a campus shuttle bus driver for about eight months. When the New Jersey Motor Vehicle Commission (NJMVC) realized the error, it revoked her passenger and school bus endorsements without providing a pre-revocation hearing.Instead of seeking review in New Jersey Superior Court, the woman filed suit in the United States District Court for the District of New Jersey. She alleged violations of Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and New Jersey’s Law Against Discrimination, as well as a procedural due process claim under 42 U.S.C. § 1983. The District Court dismissed some claims and ultimately granted summary judgment to the defendants on all remaining claims, finding she was not “qualified” for the endorsements and had no property interest in them.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The court held that the plaintiff was not a “qualified individual with a disability” under the relevant statutes because she could not meet the essential eligibility requirement of passing the hearing test for the endorsements. The court also held that, even assuming a property interest in the endorsements, due process did not require a pre-revocation hearing given the state’s strong safety interests and the availability of post-deprivation remedies. The court affirmed summary judgment for the defendants on all claims. View "Parker v. New Jersey Motor Vehicle Commission" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

In early October 2025, the President of the United States invoked his authority under 10 U.S.C. § 12406 to federalize and deploy members of the National Guard in Illinois, despite opposition from the state’s Governor. The President justified this action by citing the need to address violent assaults against federal immigration agents and property, particularly in the context of increased protests at an ICE facility in Broadview, Illinois, following the launch of “Operation Midway Blitz.” Although protests had grown in size and occasionally involved minor disruptions and isolated incidents of violence, state and local law enforcement consistently maintained control, and federal agencies reported continued success in their operations.The State of Illinois and the City of Chicago filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, challenging the federalization of the Guard. They argued that the statutory conditions for such action under § 12406 were not met, and that the move violated the Tenth Amendment and the Posse Comitatus Act. After an adversary hearing, the district court granted a temporary restraining order, finding insufficient evidence of rebellion or inability to execute federal law with regular forces, and enjoined the federalization and deployment of the Guard. The administration appealed and sought a stay of the order.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s order, applying clear error review to factual findings and de novo review to statutory interpretation. The Seventh Circuit held that the President’s decision to federalize the National Guard under § 12406 is judicially reviewable and that, even granting substantial deference to the executive, the statutory predicates for federalization were not met on the current record. The court denied the administration’s motion for a stay pending appeal as to deployment, but continued to stay the portion of the order enjoining federalization. View "Illinois v. Trump" on Justia Law

A flight attendant employed by an airline and represented by a labor union was terminated after sending graphic anti-abortion images and messages to the union president and posting similar content on social media. The employee, a pro-life Christian and vocal opponent of the union, had previously resigned her union membership but remained subject to union fees. The union’s leadership had participated in the Women’s March, which the employee viewed as union-sponsored support for abortion, prompting her messages. The airline investigated and concluded that while some content was offensive, only certain images violated company policy. The employee was terminated for violating social media, bullying, and harassment policies.Following termination, the employee filed a grievance, which the union represented. The airline offered reinstatement contingent on a last-chance agreement, which the employee declined, leading to arbitration. The arbitrator found just cause for termination. The employee then sued both the airline and the union in the United States District Court for the Northern District of Texas, alleging violations of Title VII and the Railway Labor Act (RLA), among other claims. The district court dismissed some claims, allowed others to proceed, and after a jury trial, found in favor of the employee on several Title VII and RLA claims. The court awarded reinstatement, backpay, and issued a broad permanent injunction against the airline and union, later holding the airline in contempt for its compliance with the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the judgment for the employee on her belief-based Title VII and RLA retaliation claims against the airline, remanding with instructions to enter judgment for the airline on those claims. The court affirmed the judgment against the airline on practice-based Title VII claims and affirmed all claims against the union. The court vacated the permanent injunction and contempt sanction, remanding for further proceedings, and granted the employee’s motion to remand appellate attorney’s fees to the district court. View "Carter v. Transport Workers Union of America Local 556" on Justia Law

In this case, a group consisting of an alumni association and several descendants of Serranus Clinton Hastings challenged the enactment of Assembly Bill 1936, which changed the name of “Hastings College of the Law” to “College of the Law, San Francisco” and eliminated a statutory requirement that a seat on the College’s board of directors be reserved for an heir or representative of S.C. Hastings. The plaintiffs argued that the original 1878 Act establishing the College constituted a binding contract between the State and S.C. Hastings and his descendants, and that the new legislation violated constitutional protections, including the Contract Clauses, the prohibition on bills of attainder and ex post facto laws, and the California Constitution’s provision regarding collegiate freedom.The Superior Court of the City and County of San Francisco sustained the defendants’ demurrer without leave to amend, finding that the plaintiffs failed to establish that the 1878 Act was a contract rather than an exercise of legislative power. The court also determined that Assembly Bill 1936 did not constitute a bill of attainder or ex post facto law, and that the changes to the College’s name and governance did not violate the California Constitution, particularly since the College’s board had requested the name change.The California Court of Appeal, First Appellate District, Division Four, reviewed the case de novo and affirmed the trial court’s judgment. The appellate court held that the State could not contract away its sovereign authority to manage a public institution, including the power to change the College’s name or governance structure. The court further concluded that Assembly Bill 1936 was not punitive and did not violate constitutional prohibitions on bills of attainder or ex post facto laws. The court also found no violation of the California Constitution’s collegiate freedom provision, as the changes were initiated by the College’s board. The judgment in favor of the State and College defendants was affirmed. View "Hastings College Conservation Committee v. State" on Justia Law

Two inmates in Virginia, each serving sentences for attempted aggravated murder, were initially informed by the Department of Corrections that they would be released in July 2022 due to a new state law expanding sentence credits for good behavior. This law, H.B. 5148, allowed certain inmates to earn more credits and thus reduce their incarceration time. However, after a change in the Attorney General’s office, the new Attorney General issued an advisory opinion stating that inmates convicted of inchoate offenses related to aggravated murder were not eligible for the enhanced credits. As a result, the Department reversed its earlier decision and kept the inmates incarcerated for an additional year, until the Supreme Court of Virginia later clarified that such inmates were indeed eligible for the credits and ordered their release.The inmates then filed a lawsuit in the United States District Court for the Eastern District of Virginia, seeking damages under 42 U.S.C. § 1983. They alleged that the Attorney General and the Director of Corrections violated their Eighth and Fourteenth Amendment rights by acting with deliberate indifference to their over-incarceration. The district court dismissed the complaint, finding that both officials had acted reasonably in interpreting an unsettled question of state law and that their conduct did not rise to the level of deliberate indifference or conscience-shocking behavior.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the officials’ actions did not constitute deliberate indifference under the Eighth Amendment, nor did they shock the conscience under the Fourteenth Amendment. The court emphasized that federal courts should not hold state officials personally liable for reasonable legal interpretations of unsettled state law, especially when those interpretations are made in good faith and with conventional legal reasoning. View "Swart v. Miyares" on Justia Law