Justia Government & Administrative Law Opinion Summaries

In the state of Illinois, a group of active and retired members of local police and firefighter pension funds filed a complaint against the Governor and other officials, challenging the constitutionality of Public Act 101-610. This Act amended the Illinois Pension Code and consolidated all local police and firefighter pension fund assets into two statewide pension investment funds. The plaintiffs claimed the Act violated two provisions of the Illinois Constitution: the pension protection clause and the takings clause. They argued that the Act diminished their pension benefits by diluting their voting power and control over investment decisions, and by imposing costs associated with the Act's implementation, including repayment of any transition loans. The Supreme Court of Illinois disagreed with the plaintiffs, affirming the lower courts' decisions. The court ruled that the Act does not violate the pension protection clause because the ability to vote in local pension board elections and control local pension fund investments are not constitutionally protected benefits. They also ruled that the Act does not violate the takings clause because the plaintiffs do not have a private property right in the funds that are to be transferred to the new statewide funds. The Act only changes how local fund assets are managed and invested without affecting the ultimate use of those assets to pay the benefits of local fund members. Thus, the Act remains in effect. View "Arlington Heights Police Pension Fund v. Pritzker" on Justia Law

The case was an appeal to the United States Court of Appeals for the Fifth Circuit against a lower court's decision that the structure of the Consumer Product Safety Commission (CPSC) was unconstitutional. The plaintiffs, By Two, L.P., and Consumers’ Research, argued that the CPSC's structure violated the separation-of-powers doctrine because the President could only remove the CPSC's commissioners for cause. The district court agreed with the plaintiffs, but the appellate court reversed this decision.The appellate court held that the CPSC's structure was constitutional and did not violate the separation-of-powers doctrine. The court based its decision on the Supreme Court's precedent in Humphrey’s Executor v. United States, which allowed for-cause removal protections for commissioners of independent agencies like the CPSC. The court noted that while the CPSC does exercise substantial executive power, this alone does not remove it from the protection of the Humphrey’s Executor exception. The court also pointed out that the CPSC's structure was not novel or lacking historical precedent, which further supported its constitutionality.The court emphasized that any changes to the Humphrey’s Executor exception would have to be made by the Supreme Court, not the lower courts. Until such a change occurred, the CPSC's structure remained constitutional. Thus, the court reversed the district court's decision and sent the case back to the lower court for further proceedings. View "Consumers’ Research v. Consumer Product Safety Commission" on Justia Law

In this case, the South Carolina Supreme Court upheld the constitutionality of a state statute that limits reimbursement of reestablishment expenses in condemnation proceedings to $50,000. The appellant, Applied Building Sciences, Inc., an engineering firm, was forced to move its operations when its leased building was condemned for public use by the South Carolina Department of Commerce, Division of Public Railways. The company sought reimbursement for reestablishment expenses exceeding $560,000 but was limited by state statute to $50,000. The company argued that the cap was unconstitutional under the Takings Clauses of the South Carolina and United States Constitutions. The court found that reestablishment expenses are separate from damages awardable as just compensation under both constitutions, thus upholding the constitutionality of the statutory cap. The court affirmed the lower court's granting of summary judgment in favor of the Department of Commerce, Division of Public Railways. View "Applied Building Sciences v. SC Dept of Commerce" on Justia Law

This case involves a dispute between American Precision Ammunition, L.L.C. (APA) and the City of Mineral Wells in Texas. APA and the City entered into a Tax Abatement Agreement ("Agreement") where the City promised to gift APA $150,000 and provide APA ten years of tax abatements. However, the City terminated the Agreement, claiming that the $150,000 gift was illegal under the Texas Constitution. APA sued the City for breach of contract, violation of the Texas Open Meetings Act (TOMA), and denial of federal due process and due course of law under the Texas Constitution. The district court dismissed all claims, and APA appealed.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. It held that the Agreement was illegal and unenforceable under Texas law because the City's contractual obligation to "gift" APA $150,000 constitutes a gratuitous payment of public money. The court also dismissed APA's TOMA claim as moot because there was no "agreement" to reinstate given that the Agreement was unenforceable. Furthermore, the court found that APA's due process claims failed because the promise for the $150,000 gift was void and did not constitute a contract, and therefore, APA had no protected property interest in the gift. Even assuming that APA had a property interest in the tax abatements, the court held that APA's due process and due course of law claims still fail because Texas law affords APA sufficient opportunity to pursue that claim in state court. View "American Precision v. Mineral Wells" on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, the defendant, Thomas O’Lear, was convicted of healthcare fraud, making a false statement in connection with healthcare services, and aggravated identity theft. O’Lear ran a company that provided mobile x-ray services to residents in nursing homes. However, he used the company to defraud Medicare and Medicaid programs by billing for fictitious x-rays using the identities of nursing-home residents. When an audit revealed the fraud, O’Lear attempted to conceal it by forging staff names and duplicating x-rays in the patient files.On appeal, O’Lear raised several questions. Firstly, he questioned whether his Sixth Amendment right to an impartial jury was violated by excluding individuals who had not been vaccinated against COVID-19 from the jury pool. The court ruled that the unvaccinated do not qualify as a “distinctive group” that can trigger Sixth Amendment concerns. Secondly, O’Lear questioned whether the nursing-home residents were “victims” of his fraud under a “vulnerable victims” sentencing enhancement, even though the monetary losses were suffered by Medicare and Medicaid. The court ruled that the residents were indeed victims, as O’Lear had used their identities and health records without their permission, which constituted taking advantage of them.O’Lear also challenged his two aggravated-identity-theft convictions and objected to his 180-month sentence on various grounds, but these arguments were also dismissed by the court. Ultimately, the court affirmed O’Lear's conviction and sentence. View "United States v. O'Lear" on Justia Law

The United States Court of Appeals for the Fifth Circuit denied the NAACP and other plaintiffs' emergency motions for an injunction to halt the implementation of Mississippi's House Bill 1020 (H.B. 1020). This law created a new lower court for Jackson’s Capitol Complex Improvement District (CCID), which allegedly has a disproportionate share of Jackson's white residents. The judge and prosecutors for this new court would be appointed by the Chief Justice of the Mississippi Supreme Court and the Mississippi Attorney General, respectively, rather than by locally elected officials, as is typical for other municipal courts in Mississippi. The plaintiffs claimed that this appointment process violated their Fourteenth Amendment rights to equal protection of the law.However, the court found that plaintiffs lacked standing because they failed to demonstrate a legally protected interest in the accountability of the CCID court to locally elected officials, or that H.B. 1020 would affect their voting rights by diluting the local government's control over the enforcement of its laws within the CCID's borders. The court also rejected the plaintiffs' claim of stigmatic harm, finding that they did not allege discriminatory treatment as required. Finally, the court found no merit in the argument that benefits from the CCID court would primarily go to a disproportionately white population, as the plaintiffs failed to show how H.B. 1020 would erect a barrier making it more difficult for members of one group to obtain benefits than another. View "NAACP v. Tindell" on Justia Law

In this appeal, Marcus Raper contested the Social Security Administration’s (SSA) 2020 denial of his claim for disability insurance benefits. Raper raised three arguments: (1) that the administrative law judge's (ALJ) initial lack of constitutional appointment under the Appointments Clause tainted his later constitutionally appointed review of his case, (2) that the ALJ failed to clearly articulate good cause for not fully crediting his treating physician’s medical opinion, and (3) that the ALJ wrongly discredited his subjective complaints of pain by not properly considering evidence other than objective medical evidence.The United States Court of Appeals for the Eleventh Circuit affirmed the lower court’s decision. First, the court found no Appointments Clause violation as the ALJ's initial decision, made when he was unconstitutionally appointed, had been vacated on the merits and the case was remanded to the same ALJ who was then constitutionally appointed. Second, the court held that the ALJ articulated good cause for discounting Raper's treating physician’s opinion, finding the opinion inconsistent with the record. Lastly, the court found that the ALJ had properly considered Raper’s subjective complaints in light of the record as a whole and adequately explained his decision not to fully credit Raper’s alleged limitations on his ability to work. View "Raper v. Commissioner of Social Security" on Justia Law

In this case, the Sitka Tribe of Alaska challenged the State of Alaska's management of a commercial fishery, arguing that it harmed a subsistence fishery. The tribe argued that the state violated the subsistence priority statute and the common use and sustained yield clauses in the Alaska Constitution. The tribe also claimed that the state was misinterpreting a regulation controlling the fishery and sought a preliminary injunction to prevent the state from managing the fishery according to that interpretation during the upcoming season. The superior court denied the preliminary injunction.The tribe eventually won on its statutory and regulatory claim, but the superior court denied its constitutional claim and its request for attorney’s fees. The tribe appealed to the Supreme Court of Alaska.The Supreme Court of Alaska affirmed the superior court’s decisions. It held that the hard look doctrine, requiring agencies to consider all relevant information, already existed and there was no need to create a constitutional requirement not in the plain language of Article VIII, Section 4 of the Alaska Constitution. The court also declined to review the tribe’s motion for a preliminary injunction under the public interest exception, as the issue was moot and did not justify application of the public interest exception. Lastly, the court held that the superior court did not abuse its discretion by declining to award attorney’s fees as the tribe had not shown that the superior court's decision was arbitrary, capricious, manifestly unreasonable, or stemmed from an improper motive. View "Sitka Tribe of Alaska v. State of Alaska" on Justia Law

The case involves Brandon Peterson, an inmate at Washington County Jail (WCJ), who filed a lawsuit alleging violations of his constitutional rights by various jail officials. The United States Court of Appeals for the Eighth Circuit, reviewing the case, had to decide on numerous instances of alleged excessive force, failure to intervene, and deliberate indifference to serious medical needs, as well as constitutional and state law claims.The court found that on several occasions of alleged excessive force, the officers' actions were justified given Peterson's disruptive and threatening behavior. Consequently, the court granted qualified immunity to the officers involved in these incidents. In the case of the failure to intervene claims, the court decided that without an underlying constitutional violation, there can be no liability for failure to intervene, resulting in the officers being granted qualified immunity for these claims as well.On the issue of deliberate indifference to Peterson's mental health condition, the court found that the prison officials had made efforts to address his condition and had not acted with deliberate disregard for his health. Therefore, the court reversed the district court's denial of qualified immunity to the officials involved.Regarding Peterson's claim of being subjected to unconstitutional conditions of confinement, the court remanded the case to the district court for it to address this issue. The court also remanded the case to the district court to decide on the state law and Monell claims. As such, the Appeals Court reversed in part, dismissed in part, and vacated in part the district court's decision, remanding the case for further proceedings consistent with the court’s opinion. View "Peterson v. Heinen" on Justia Law

The case involves the defendant, Jason Thomas Wilcox, who was taken into police custody for public intoxication under ORS 430.399, a noncriminal statute. During this process, the police seized and inventoried his backpack, discovering a butterfly knife. As Wilcox had a prior felony conviction, he was charged and convicted for being a felon in possession of a restricted weapon under ORS 166.270(2). Wilcox appealed, arguing that the seizure of his backpack was unlawful under Article I, section 9, of the Oregon Constitution. The Court of Appeals agreed, finding that the seizure was unlawful, and based its decision on a previous case, State v. Edwards.The Supreme Court of the State of Oregon vacated the decision of the Court of Appeals and remanded the case for further proceedings. The Supreme Court found that the Court of Appeals had erred in its analysis because it treated the seizure as a criminal one rather than an administrative one. The Court pointed out that when a person or their property is seized under ORS 430.399, the seizure is administrative, not criminal, and such seizures must comply with a different set of constitutional standards. The Court also clarified that the state’s interference with a person’s possessory or ownership interests constitutes a seizure, regardless of whether the person objects to the interference.The Supreme Court held that the seizure of the backpack was indeed a seizure. However, it did not decide whether the seizure was lawful, instead remanding the case to the Court of Appeals to determine whether ORS 430.399, or some other source of authority, authorized the seizure of defendant’s backpack and if so, whether that seizure was effectuated in accordance with the requirements of State v. Atkinson, which set the framework for assessing the constitutionality of an administrative search or seizure. View "State v. Wilcox" on Justia Law