Justia Government & Administrative Law Opinion Summaries

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

Owners of developed commercial and residential properties in Athens-Clarke County challenged the county’s stormwater utility charge, arguing that it was an unconstitutional tax rather than a fee. The charge, established by county ordinances in 2004, funds stormwater management services required by federal law, with the amount assessed based on impervious surface area and land-use classification. The ordinance exempts certain properties, such as public roads and sidewalks, and offers credits for on-site stormwater management. The funds collected are used for flood prevention, pollution minimization, and compliance with federal regulations.Previously, the Superior Court of Athens-Clarke County granted summary judgment to the county, finding that the stormwater utility charge was a fee, not a tax, and thus not subject to the Georgia Constitution’s taxation uniformity provision. This decision relied on the Georgia Supreme Court’s earlier ruling in Homewood Village, LLC v. Unified Government of Athens-Clarke County, which had addressed the same ordinance and held it imposed a fee rather than a tax. The appellants also pursued related claims in federal court, but those were dismissed on abstention grounds.On appeal, the Supreme Court of Georgia affirmed the trial court’s decision. The court held that its prior decision in Homewood Village, LLC v. Unified Government of Athens-Clarke County controlled, reaffirming that the stormwater utility charge is a fee and not a tax, and therefore the uniformity provision does not apply. The court also rejected the appellants’ arguments that the charge constituted an unconstitutional taking under the Georgia and United States Constitutions, finding no basis for such a claim. Finally, the court found that the trial court had properly applied the summary judgment standard and had not improperly resolved factual disputes. The judgment in favor of the county was affirmed. View "HOMEWOOD ASSOCIATES INC. v. UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY" on Justia Law

An inmate in Missouri, facing imminent execution, requested that his two daughters—both ordained ministers—be allowed to serve as his spiritual advisors in the execution chamber. One daughter would administer communion and anoint him with oil, then move to the viewing area, while the other would enter the chamber to pray over and touch him during the execution. The Missouri Department of Corrections denied this request, citing security concerns, but offered alternatives: a non-relative spiritual advisor, prison clergy, or his attorney could perform the rituals, with his daughters directing the proceedings from behind glass.After exhausting administrative remedies and just five days before his scheduled execution, the inmate filed suit in the United States District Court for the Eastern District of Missouri. He alleged that the Department’s refusal violated his rights under the First Amendment’s Free Exercise Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA). He sought a preliminary injunction and a stay of execution. The district court denied his requests and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of a stay of execution. The court focused on whether the inmate had shown a likelihood of success on the merits, specifically whether the Department’s policy imposed a “substantial burden” on his religious exercise under RLUIPA. The court found that, while the inmate preferred his daughters as spiritual advisors, he did not demonstrate that only they could perform the rituals in accordance with his beliefs. The court concluded that the Department’s alternatives did not significantly inhibit his religious exercise and that security concerns justified the restriction. The Eighth Circuit denied the motion for a stay of execution. View "Shockley v. Adams" on Justia Law

A longtime Alaska resident with extensive experience in personal-use and commercial fishing brought suit against the State of Alaska, alleging that the State’s management of chinook and chum salmon populations in the Yukon and Kuskokwim Rivers violated the sustained yield principle mandated by the Alaska Constitution. The plaintiff claimed that the significant decline in these salmon populations since statehood was evidence of unconstitutional management. He did not challenge any specific policy, regulation, or action, but instead sought a declaration that the State’s management had been unconstitutional for decades and requested injunctive relief to compel the State to fulfill its sustained yield obligations.The Superior Court for the Fourth Judicial District, Bethel, granted the State’s motion to dismiss for failure to state a claim. The court found that the claims presented nonjusticiable political questions reserved for the legislative branch, that the plaintiff failed to allege a concrete injury or identify specific State actions causing harm, and that deference to agency expertise was warranted in the absence of a challenge to a particular policy or action.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s dismissal. The Supreme Court held that the claims for injunctive relief were nonjusticiable because they would require the judiciary to make initial fisheries policy determinations, a function constitutionally committed to the legislative and executive branches. The Court further held that the claim for declaratory relief was not justiciable because it would not clarify or settle the legal relations between the parties, as it did not identify specific actions or policies to be addressed. The Court concluded that, absent a challenge to a particular State action or policy, the claims did not present an actual controversy suitable for judicial resolution. View "Forrer v. State of Alaska" on Justia Law

Several months before an election, complaints were filed with the Alaska Public Offices Commission alleging that two political groups, A Stronger Alaska and the Republican Governors Association, had violated Alaska’s campaign finance laws by coordinating with a gubernatorial campaign and failing to comply with disclosure requirements. The Commission initiated expedited proceedings, held hearings where officials from the groups testified, and then chose not to make a final determination on the alleged violations. Instead, the Commission remanded the matters to its staff for further investigation on a regular, non-expedited basis. The Commission’s staff subsequently issued administrative subpoenas seeking documents and communications from the groups, but the groups refused to comply.The Commission sought judicial enforcement of its subpoenas in the Superior Court for the State of Alaska, Third Judicial District. The groups opposed enforcement, arguing that the subpoenas were unnecessary because the Commission already had relevant testimony, that further investigation was barred by res judicata, and that the process violated their due process rights. They also challenged the constitutionality of the statutory scheme authorizing the expedited process. The superior court rejected all of these arguments, granted summary judgment in favor of the Commission, and ordered enforcement of the subpoenas.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s decision. The court held that the subpoenas were not unreasonable or oppressive simply because prior testimony had been given, as documentary evidence could still be relevant. The court also held that res judicata did not apply because the Commission had not issued a final decision on the merits, and that the process did not violate substantive due process or result in an absurd or unconstitutional statutory scheme. The court affirmed the order granting summary judgment to the Commission. View "Republican Governors Association v. Hebdon" on Justia Law

A federal inmate serving a 210-month sentence challenged the method used by the Federal Bureau of Prisons (BOP) to calculate his good conduct time credits under 18 U.S.C. § 3624(b)(1), as amended by the First Step Act of 2018. The inmate argued that, following the amendments, he should receive a full 54 days of good conduct time credit for the last six months of his sentence, rather than a prorated amount. The BOP, however, interpreted the amended statute to require prorating the credit for any partial year, resulting in the inmate receiving 26 days of credit for the final six months instead of 54.The United States District Court for the District of New Jersey denied the inmate’s habeas petition. The court found that the plain language of the amended statute allowed for proration of good conduct time credits for partial years. As an alternative basis, the District Court also relied on Chevron deference to uphold the BOP’s interpretation. The court rejected the inmate’s additional claims under the Administrative Procedure Act (APA) and the Due Process Clause, finding them either precluded by statute or inapplicable to the rulemaking context.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory interpretation de novo. The Third Circuit affirmed the District Court’s judgment, holding that the First Step Act’s amendments, while deleting the word “prorated,” introduced language (“for each year”) that sets a rate of 54 days per year, thereby requiring proration for any partial year. The court concluded that the statute’s natural reading supports the BOP’s method of prorating credits for the last portion of a sentence. The Third Circuit also rejected the inmate’s constitutional and APA-based arguments, and found no basis for applying the rule of lenity. View "Thieme v. Warden Fort Dix FCI" on Justia Law

Petitioners, resident taxpayers and registered voters in Oklahoma County, challenged the constitutionality of Senate Bill 632, which sought to create business court divisions within the district courts of Oklahoma County and Tulsa County. The Act provided for the appointment of business court judges by the Governor, with confirmation by the Senate and candidate lists supplied by the Speaker of the House. It also set forth qualifications, terms, salaries, and operational details for these judges and courts. Petitioners argued that the Act violated their constitutional rights, particularly the right to elect district judges, and would result in the unlawful expenditure of public funds.Prior to review by the Supreme Court of the State of Oklahoma, the Honorable Lonnie Paxton and Kyle Hilbert, legislative leaders named as respondents, moved for dismissal based on legislative immunity, which the court granted. The Governor, the remaining respondent, moved to dismiss the case, arguing he was not a proper party. The court denied this motion, finding the Governor’s role in appointing business court judges central to the dispute. The Oklahoma Association for Justice filed an amicus brief supporting Petitioners. The court assumed original jurisdiction, issued a temporary stay of the Act’s effectiveness, and heard oral arguments.The Supreme Court of the State of Oklahoma held that Petitioners had standing as both taxpayers and voters. The court found Senate Bill 632 unconstitutional because it violated Article VII, Section 9 of the Oklahoma Constitution by circumventing the requirement that district judges be elected by voters. The court further determined that the unconstitutional provisions were not severable from the rest of the Act, rendering the entire Act void and unenforceable. The petition for declaratory relief was granted, and the temporary stay remained in effect pending any rehearing. View "White v. Stitt" on Justia Law

Novo Nordisk, a pharmaceutical manufacturer, challenged the implementation of the Drug Price Negotiation Program established by the Inflation Reduction Act of 2022. The Program requires the Department of Health and Human Services, through the Centers for Medicare and Medicaid Services (CMS), to negotiate prices for certain high-expenditure drugs covered by Medicare. In the first round of selections, CMS grouped six of Novo Nordisk’s insulin aspart products as a single “negotiation-eligible drug” and selected them for price negotiation. Novo Nordisk signed the required agreements to participate but subsequently filed suit, arguing that CMS’s grouping of its products and the procedures used to implement the Program violated statutory and constitutional provisions.The United States District Court for the District of New Jersey granted summary judgment in favor of the government. The court found it lacked subject matter jurisdiction to review CMS’s decision to treat the six products as one drug due to a statutory bar on judicial review. It also held that Novo Nordisk lacked standing to challenge the identification of more than ten drugs for the initial pricing period. The court rejected Novo Nordisk’s claims under the unconstitutional conditions doctrine, the Due Process Clause, the nondelegation doctrine, and the First Amendment, concluding that the Program did not deprive the company of a protected property interest, that Congress provided an intelligible principle to guide CMS, and that the Program primarily regulated conduct rather than speech.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that the statutory bar on judicial review precluded consideration of Novo Nordisk’s challenge to the grouping of its products. The court also held that CMS was authorized to implement the Program through guidance for the initial years without notice and comment rulemaking, that the Act did not violate the nondelegation doctrine or the Due Process Clause, and that Novo Nordisk’s First Amendment claim was foreclosed by precedent. View "Novo Nordisk Inc. v. Secretary US Dept & Health and Human Services" on Justia Law

The case concerns challenges to Executive Order No. 14160, issued in January 2025, which seeks to deny birthright citizenship to children born in the United States after its effective date if their fathers are not U.S. citizens or lawful permanent residents and their mothers are either unlawfully or temporarily present in the country. Plaintiffs include individual immigrants, nonprofit organizations, and a coalition of states and local governments. They allege that the Executive Order violates the Citizenship Clause of the Fourteenth Amendment, 8 U.S.C. § 1401(a), the equal protection component of the Fifth Amendment, the Separation of Powers doctrine, and the Administrative Procedure Act. The plaintiffs seek declaratory and injunctive relief to prevent enforcement of the Order.The United States District Court for the District of Massachusetts granted preliminary injunctions to both sets of plaintiffs, finding they were “exceedingly likely” to succeed on their claims under the Citizenship Clause and § 1401(a). The injunctions barred federal agencies and officials from enforcing the Executive Order against the plaintiffs and, in the case brought by the states, issued a nationwide injunction to provide complete relief. The government appealed, challenging the plaintiffs’ standing, the scope of the injunctions, and the merits of the constitutional and statutory claims.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s findings that the plaintiffs have Article III standing and are likely to succeed on the merits. The First Circuit held that the Executive Order’s denial of birthright citizenship to children born in the United States under the specified circumstances violates both the Citizenship Clause of the Fourteenth Amendment and 8 U.S.C. § 1401(a), as interpreted by United States v. Wong Kim Ark and subsequent precedent. The court affirmed the preliminary injunctions in part, vacated them in part as to agency defendants, and remanded for further proceedings consistent with its opinion. View "Doe v. Trump" on Justia Law

A group of out-of-state pig farmers and a pork processor challenged a Massachusetts law that prohibits the use of certain confinement methods for breeding pigs (specifically, gestation crates) and bans the sale in Massachusetts of pork products derived from pigs confined in such a manner. The plaintiffs, who operate outside Massachusetts and use these confinement methods, argued that the law discriminates against out-of-state producers and is preempted by federal statutes. The law was enacted by ballot initiative and became enforceable after the Supreme Court’s decision in National Pork Producers Council v. Ross.The United States District Court for the District of Massachusetts dismissed most of the plaintiffs’ claims, including those based on the Privileges and Immunities Clause, preemption by the Federal Meat Inspection Act (FMIA) and the Packers and Stockyards Act (PSA), the Full Faith and Credit Clause, the Due Process Clause, and the Import-Export Clause. The court allowed the dormant Commerce Clause claim to proceed, but ultimately granted summary judgment against the plaintiffs on that claim as well, after severing a provision of the law that it found discriminatory (the “slaughterhouse exemption”). The court found that the remaining provisions of the law did not discriminate against out-of-state interests and did not impose a substantial burden on interstate commerce.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that the Massachusetts law does not discriminate against out-of-state producers in purpose or effect, does not impose a substantial burden on interstate commerce under the Pike balancing test, and is not preempted by the FMIA or PSA. The court also rejected the plaintiffs’ claims under the Privileges and Immunities Clause, Full Faith and Credit Clause, Due Process Clause, and Import-Export Clause. The court found no procedural error in the district court’s handling of the case. View "Triumph Foods, LLC v. Campbell" on Justia Law