Justia Government & Administrative Law Opinion Summaries

Radio Communications Corporation (RCC), a telecommunications and media company, petitioned for review of a final order issued by the Federal Communications Commission (FCC) implementing the Low Power Protection Act (LPPA). The LPPA allows low power television (LPTV) stations to apply for an upgrade to a Class A license if they meet certain criteria, including operating in a Designated Market Area (DMA) with not more than 95,000 television households. The FCC's order adopted this limitation and used Nielsen’s Local TV Report to determine a station’s DMA.RCC operates an LPTV station, W24EZ-D, in Connecticut, which is licensed to serve Allingtown, a neighborhood of West Haven with fewer than 15,000 television households. However, the station is part of the Hartford-New Haven DMA, which has approximately one million television households. RCC challenged the FCC's order, arguing that the size limitation should apply to a station’s community of license, not its DMA. RCC also raised other statutory and constitutional arguments, including claims that the order contravenes section 307(b) of the Communications Act, violates the Commerce Clause, improperly delegates legislative authority to Nielsen, and restricts programming content in violation of the First Amendment.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the FCC's order adheres to the best reading of the LPPA, which clearly limits Class A license eligibility to LPTV stations operating in a DMA with not more than 95,000 television households. The court found that the FCC properly defined DMA according to Nielsen’s data, as authorized by Congress, and that the statute does not reference "community of license." The court also rejected RCC's constitutional arguments, finding that the FCC's interpretation did not violate the Commerce Clause or the nondelegation doctrine. Consequently, the court denied RCC's petition for review. View "Radio Communications Corporation v. FCC" on Justia Law

Spirit AeroSystems, a manufacturer of airplane parts, was issued a Request to Examine (RTE) by the Attorney General of Texas, W. Kenneth Paxton. The RTE statute allows the Attorney General to inspect business records without providing an opportunity for precompliance judicial review. Spirit challenged the statute as facially unconstitutional, arguing it violated the Fourth Amendment by not allowing precompliance review.The United States District Court for the Western District of Texas agreed with Spirit, finding the RTE statute unconstitutional for failing to provide precompliance review and issued a permanent injunction preventing the Attorney General from enforcing the RTEs against Spirit. The court's decision was based on the precedent set by City of Los Angeles v. Patel, which requires an opportunity for precompliance review to avoid Fourth Amendment violations.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Texas Supreme Court issued a decision in Paxton v. Annunciation House, Inc., which interpreted the RTE statute to include the required opportunity for precompliance review through Texas Rule of Civil Procedure 176.6. This rule allows recipients of administrative subpoenas to seek a protective order before compliance is required.Given the Texas Supreme Court's interpretation, the Fifth Circuit vacated the district court's judgment and remanded the case for further proceedings consistent with the new interpretation, which now provides the necessary precompliance review to satisfy Fourth Amendment requirements. View "Spirit Aerosystems v. Paxton" on Justia Law

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

The case involves a challenge to Michigan's newborn screening program, which collects blood samples from newborns to test for diseases. The plaintiffs, consisting of parents and their children, argue that the program's retention and use of these blood samples without consent violate their Fourth and Fourteenth Amendment rights. The plaintiffs claim that the state's actions constitute a coercive, non-consensual taking and keeping of baby blood for the state's profit.Initially, the United States District Court for the Eastern District of Michigan dismissed the plaintiffs' complaint. However, a prior panel of the United States Court of Appeals for the Sixth Circuit reversed and remanded several claims, allowing the plaintiffs to pursue their Fourth and Fourteenth Amendment claims for injunctive and declaratory relief. On remand, the district court granted judgment in favor of the plaintiffs on nearly all their remaining claims and ordered the defendants to return or destroy the stored blood spots and data.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's judgment. The appellate court held that the defendants' actions of storing and using the blood spots and data did not violate the plaintiffs' Fourteenth Amendment substantive-due-process rights, as these actions did not constitute medical care or intrude on the parents' right to direct their children's medical care. Additionally, the court found that the plaintiffs failed to prove a possessory interest in the blood spots and data, which is necessary to establish a Fourth Amendment seizure claim. Consequently, the appellate court vacated the injunction requiring the defendants to destroy the stored data. View "Kanuszewski v. Michigan Dep't of Health & Human Services" on Justia Law

The case involves a dispute between the Wisconsin State Legislature and the Wisconsin Department of Public Instruction (DPI) regarding the governor's partial veto power and the allocation of funds for literacy programs. The legislature argued that the governor exceeded his constitutional authority by partially vetoing a bill that was not an appropriation bill. DPI and the governor contended that the legislature's Joint Committee on Finance (JCF) improperly withheld funds appropriated for DPI's literacy programs.The Dane County Circuit Court granted summary judgment in part for each party. The court concluded that the governor did not exceed his constitutional boundaries in partially vetoing the bill and that JCF did not improperly withhold funds from DPI. The court reasoned that the bill in question was an appropriation bill and that the governor's partial veto was valid. However, the court also held that DPI was not entitled to the funds appropriated to JCF.The Wisconsin Supreme Court reviewed the case and held that the governor breached his constitutional boundaries because the bill he partially vetoed was not an appropriation bill. The court reaffirmed the "four corners rule," which requires that an appropriation bill must set aside public funds for a public purpose within its text. The court concluded that the bill in question did not meet this requirement and, therefore, was not subject to the governor's partial veto authority. The court also held that JCF did not improperly withhold funds from DPI, as the funds were lawfully appropriated to JCF. Consequently, the court affirmed in part and reversed in part the circuit court's summary judgment order. View "Wisconsin State Legislature v. Wisconsin Department of Public Instruction" on Justia Law

Fred Hodara filed a lawsuit against the Oklahoma Department of Corrections (DOC) for alleged violations of the Open Records Act, seeking access to records related to the drugs used in executions. Initially, the DOC claimed it had no responsive records, but later provided some documents, albeit heavily redacted. Hodara sought declaratory and injunctive relief, arguing that the DOC's refusal to provide the requested material was unlawful. The DOC moved to dismiss the case, citing a statutory exemption under Title 22, Section 1015(B), which was later amended in 2024 to broaden the scope of confidentiality.The district court denied both parties' motions for summary judgment due to unresolved factual disputes. However, after the statutory amendment, the DOC filed a second motion to dismiss, which the court granted, concluding that the amended statute precluded Hodara's Open Records Act claim. Hodara appealed the dismissal, challenging the retroactive application and constitutionality of the amended statute.The Supreme Court of the State of Oklahoma reviewed the case de novo, focusing on the October 4, 2024, order. The court found that the 2024 amendment to Section 1015(B) did not create a new confidentiality privilege but clarified the existing one. The court held that the amendment could be applied retroactively and did not violate the Oklahoma Constitution. The court affirmed the district court's decision, concluding that the DOC's refusal to provide the requested records was lawful under the amended statute. View "HODARA v. OKLAHOMA DEPARTMENT OF CORRECTIONS" on Justia Law

Arkansas Act 629 criminalized many previously legal hemp products. A coalition of affected businesses sued state officers, alleging that Act 629 is unconstitutional. The district court granted the plaintiffs' motion for a preliminary injunction and denied the state's motion to dismiss the Governor and Attorney General.The United States District Court for the Eastern District of Arkansas found that the plaintiffs were likely to succeed on the merits of their Supremacy Clause and due process claims. The court concluded that the 2018 Farm Bill likely preempted Act 629 and that the Act was likely void for vagueness. The court also found that the Governor and Attorney General were not entitled to sovereign immunity because they were sufficiently connected to the enforcement of Act 629.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the 2018 Farm Bill did not expressly preempt Act 629 because the Act's savings clause allowed for the continuous transportation of hemp through Arkansas. The court also found that Act 629 did not conflict with the 2018 Farm Bill's purpose of legalizing hemp production, as the federal law allows states to regulate hemp production more stringently. Additionally, the court concluded that Act 629 was not unconstitutionally vague, as the terms "continuous transportation," "synthetic substance," and "psychoactive substances" were sufficiently clear.The court further held that the Governor and Attorney General were entitled to sovereign immunity because they did not have a sufficient connection to the enforcement of Act 629. The court vacated the preliminary injunction, reversed the order denying the motion to dismiss the Governor and Attorney General, and remanded the case for further proceedings. View "Bio Gen LLC v. Sanders" on Justia Law

A public benefit corporation, Lawyers for Fair Reciprocal Admissions (LFRA), challenged local rules of federal district courts in the Ninth Circuit. These rules require attorneys seeking general admission to be members in good standing of the bar of the state where the district court is located. LFRA argued that these rules prevent its members, who are barred in states outside the Ninth Circuit and do not wish to join another state bar, from seeking general admission to these federal district courts.The United States District Court for the District of Arizona dismissed LFRA’s amended complaint with prejudice. The court found that LFRA had standing to bring claims on behalf of its members, except for the Sixth Amendment claim, which lacked standing. The court dismissed the remaining claims for failure to state a claim, concluding that the Admission Rules did not violate constitutional, statutory, or procedural grounds as alleged by LFRA.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal with prejudice. The Ninth Circuit held that the Admission Rules are constitutional and do not violate separation of powers, federalism principles, the Privileges and Immunities Clauses, the Equal Protection Clause, the First Amendment, the Full Faith and Credit Act, the Rules Enabling Act, or procedural due process. The court also found that Rules 1 and 83 of the Federal Rules of Civil Procedure do not create a private right of action. The Ninth Circuit concluded that the district court did not abuse its discretion in dismissing the amended complaint without leave to amend, as the complaint could not be saved by amendment. The court also upheld the denial of LFRA’s motion for judgment on the pleadings as procedurally premature. View "Lawyers for Fair Reciprocal Admissions v. United States" on Justia Law

Clifford Bain was seriously injured when a bus owned and operated by the City of Cheyenne collided with him while he was riding his motorcycle. Bain filed a complaint against the bus driver and the City under the Wyoming Governmental Claims Act (WGCA). The bus driver and the City admitted liability but claimed immunity from any liability exceeding $250,000 under the WGCA. Bain then filed a motion for partial summary judgment, arguing that the limitation in § 1-39-118(a)(i) of the WGCA was unconstitutional under Article 10, § 4(a) of the Wyoming Constitution. The district court denied Bain’s motion, declaring the statute constitutional. Bain subsequently filed a petition for writ of review with the Wyoming Supreme Court.The district court denied Bain’s motion for partial summary judgment, holding that § 1-39-118(a)(i) of the WGCA is not a limitation on damages but rather a limitation on the waiver of immunity. Bain then filed a petition for writ of review, which the Wyoming Supreme Court granted.The Wyoming Supreme Court reviewed the case de novo and affirmed the district court’s decision. The Court held that § 1-39-118(a)(i) is a limitation on the waiver of immunity under the WGCA and not a limitation on damages, thus it does not violate Article 10, § 4(a) of the Wyoming Constitution. The Court emphasized that the statute limits the legal responsibility or obligation of governmental entities and is consistent with the legislative intent to balance the equities between injured persons and taxpayers. The Court concluded that Bain did not meet his burden of proving the statute unconstitutional. View "Bain v. City of Cheyenne" on Justia Law

The case involves a challenge to the ward map adopted by the Jersey City Ward Commission following the 2020 federal census. The Commission found a 59% population deviation between the most and least populous wards, which exceeded the maximum allowed by the Municipal Ward Law (MWL). The Commission created a new map with a 1.8% deviation and revised the boundaries of all six wards. Plaintiffs, including individuals and community organizations, argued that the new map failed to meet the MWL’s compactness requirement and violated equal protection principles under the New Jersey Constitution. They also claimed a violation of the New Jersey Civil Rights Act (NJCRA).The trial court concluded that the Commission’s map created sufficiently compact wards under the MWL and dismissed the plaintiffs’ statutory and constitutional claims. The Appellate Division reversed the dismissal of the MWL claims, remanding for factfinding on whether the Commission’s determination of compactness had a rational basis. It affirmed the dismissal of the equal protection and NJCRA claims.The New Jersey Supreme Court reviewed the case, focusing on the MWL, equal protection, and NJCRA claims. The Court held that the Commission’s map was a proper exercise of its discretion under the MWL. It found that the Commission was not required to use mathematical measures of compactness or consider communities of interest in its determination. The Court reversed the Appellate Division’s remand for additional factfinding, reinstating the trial court’s judgment on the MWL claim. The Court also affirmed the dismissal of the equal protection and NJCRA claims, concluding that the Commission’s compliance with the MWL negated the equal protection claim and that no statutory or constitutional violation occurred to support the NJCRA claim. View "Jersey City United Against the New Ward Map v. Jersey City Ward Commission" on Justia Law