Justia Government & Administrative Law Opinion Summaries

A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information.Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. The case was removed to the United States District Court for the Western District of Missouri. The superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of immunity de novo. The appellate court held that the current superintendent was a proper Ex parte Young defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity. View "Cunningham v. Olson" on Justia Law

A United States citizen originally from Yemen filed family-based visa petitions (Form I-130) in 2002 on behalf of several relatives, including his stepdaughter. The immigration authorities sent a notice of intent to deny these petitions and a subsequent denial letter to the address provided on the petition. The petitioner did not respond, and the petitions were denied. Twenty years later, the petitioner sued, asserting that he never received the notices because the agency had mistakenly sent them to an address where he did not live, and that this lack of notice violated the Due Process Clause and the Administrative Procedure Act. He attached a redacted version of his petition to his complaint, omitting the address at issue.The United States District Court for the Northern District of Illinois, Eastern Division, initially denied the government’s motion to dismiss, finding that the complaint plausibly supported the application of the discovery rule or equitable tolling and otherwise stated a claim. However, when the government moved for judgment on the pleadings and submitted an unredacted copy of the I-130 petition showing that the petitioner himself had listed the very address to which the notices were sent, the court found this document dispositive. The petitioner did not meaningfully contest the authenticity or content of the unredacted petition, failed to appear at the hearing, and did not object to the government’s supporting affidavit.On appeal, the United States Court of Appeals for the Seventh Circuit held that the unredacted I-130 petition conclusively refuted the petitioner’s factual claims. The court held that when a plaintiff’s own incorporated documents contradict the complaint’s allegations, those documents control. The court affirmed the district court’s entry of judgment for the government, finding that the due process and APA claims failed as a matter of law. View "Muthana v Mullin" on Justia Law

During the summer of 2025, protests erupted in Southern California in response to federal immigration raids. Protesters, legal observers, and journalists alleged that officers of the Department of Homeland Security (DHS), including agents from Immigration and Customs Enforcement, the Federal Protective Services, and Customs and Border Protection, used crowd control weapons indiscriminately against them. Multiple individuals, including members of the press and protesters, suffered significant physical injuries during these events, even when they were complying with police orders or were not near disruptive protest activity.Several individual journalists, legal observers, protesters, and two press organizations filed suit in the United States District Court for the Central District of California. They alleged violations of their First Amendment rights, specifically the right to be free from retaliation for engaging in protected activities and the right of public access to protests. The district court issued a preliminary injunction to protect the rights of protesters, journalists, and legal observers, finding that the defendants’ conduct chilled First Amendment activity. The government appealed, arguing that the injunction was overly broad and legally unsound.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision. The Ninth Circuit held that the plaintiffs were likely to succeed on their First Amendment retaliation claims, that both individual and organizational plaintiffs had standing, and that the other requirements for a preliminary injunction were met. However, the court found that the scope of the injunction was overbroad because it extended relief to non-parties and included provisions not narrowly tailored to the specific harms alleged. The Ninth Circuit affirmed the district court’s decision to issue a preliminary injunction but vacated and remanded the case for the district court to craft a narrower injunction consistent with its opinion. View "LOS ANGELES PRESS CLUB V. NOEM" on Justia Law

The Montana legislature enacted a law, HB 937, and associated administrative rules that imposed new licensure and regulatory requirements specifically on abortion clinics, which were defined as facilities providing abortion-inducing drugs or performing surgical abortions to at least five patients per year. These requirements did not apply to clinics that provided identical medications and procedures exclusively for miscarriage management. Plaintiffs, including two clinics and a nurse practitioner, challenged the law and rules, arguing that they violated the equal protection and privacy rights guaranteed by the Montana Constitution. They asserted that these new requirements could force them to cease providing abortion care, thereby restricting their patients’ access to such services.After the plaintiffs filed their complaint, the First Judicial District Court, Lewis and Clark County, initially granted a temporary restraining order and later a preliminary injunction, preventing enforcement of HB 937 and the associated rules. The District Court found that the plaintiffs were likely to succeed on their equal protection claim, that irreparable harm was likely absent an injunction, that the balance of equities favored the plaintiffs, and that an injunction was in the public interest. The court determined that the law treated similarly situated providers—those giving identical care for either miscarriage or abortion—differently solely based on the purpose of the treatment. The court applied strict scrutiny, finding that the state had not demonstrated a compelling interest or that the law was narrowly tailored.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s preliminary injunction. The Supreme Court held that HB 937 and the rules likely violate the Montana Constitution’s guarantee of equal protection by subjecting abortion providers to unique, burdensome licensing requirements not imposed on providers of identical miscarriage care, thus likely infringing on the fundamental right to privacy. The Court concluded that the plaintiffs met all four elements required for a preliminary injunction and affirmed the lower court’s order in its entirety. View "All Families v. State" on Justia Law

A class of inmates at the Louisiana State Penitentiary alleged that the prison’s medical care was constitutionally inadequate and that the facility failed to comply with the Americans with Disabilities Act and the Rehabilitation Act. The lawsuit began in 2015, and evidence was introduced at trial in 2018. In 2021, the United States District Court for the Middle District of Louisiana issued a lengthy opinion finding systemic Eighth Amendment violations and ADA/RA noncompliance. While prison officials began making improvements ahead of a scheduled remedial trial, the district court later issued a Remedial Opinion and Order, prescribing detailed institutional changes and appointing special masters to oversee compliance.The district court’s Remedial Order required the state to bear the costs of three special masters, directed broad institutional reforms, and did not expressly adhere to the limitations imposed by the Prison Litigation Reform Act (PLRA). The court entered final judgment in favor of the plaintiffs, retaining jurisdiction only for compliance procedures. After entry of judgment, the defendants appealed. During the appeal, a panel of the United States Court of Appeals for the Fifth Circuit stayed the Remedial Order. The Fifth Circuit, sitting en banc, subsequently reviewed whether it had appellate jurisdiction and the validity of the district court’s orders.The United States Court of Appeals for the Fifth Circuit held that it had appellate jurisdiction under 28 U.S.C. § 1291 or, alternatively, § 1292(a)(1). The Fifth Circuit found that the district court’s Remedial Order violated the PLRA by failing to apply the statutory needs-narrowness-intrusiveness standard, improperly appointing multiple special masters, and requiring the state to pay their fees. The Fifth Circuit also concluded that the district court erred by disregarding ongoing improvements to prison medical care and by misapplying the standards for injunctive relief under the Eighth Amendment and the ADA/RA. The court vacated the district court’s judgment and remanded for further proceedings. View "Parker v. Hooper" on Justia Law

An inmate in an Arkansas maximum-security unit, who is Muslim, challenged a change in prison policy regarding meals served during Ramadan. Previously, fasting Muslims received a “double-portion” dinner after sunset and a standard breakfast before dawn. In 2023, the prison discontinued the double-portion dinner, providing only standard portions for both meals, but continued to serve them at the appropriate times for religious observance. The meals together provided at least 2,000 calories per day. The inmate often skipped the provided breakfast during Ramadan, preferring to eat commissary food instead, which he could easily obtain.The United States District Court for the Eastern District of Arkansas, Central Division, granted summary judgment to the prison officials, concluding that the new meal policy did not violate the inmate’s rights under the Eighth Amendment or the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the inmate’s allegations of hunger and physical symptoms were not corroborated by medical evidence, and that the inmate’s ability to supplement with commissary food meant he was not denied adequate nutrition.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the prison’s policy did not impose a substantial burden on the inmate’s religious exercise under RLUIPA. The court emphasized that the inmate’s claimed need for 3,000 calories was not rooted in religious belief, but rather based on the institution’s general meal plan. The record showed that the meals provided were nutritionally adequate and that the inmate voluntarily skipped breakfast, supplementing from the commissary. Because the inmate failed to show a genuine dispute of material fact regarding a substantial burden on his religious exercise, the Eighth Circuit affirmed the district court’s judgment. View "Holt v. Payne" on Justia Law

Four women incarcerated at the Huron Valley Correctional Facility in Michigan suffered from persistent, painful rashes between 2016 and 2019. Despite repeated complaints, medical staff—contracted through Corizon Health—failed to diagnose scabies, instead providing ineffective treatments and attributing the condition to environmental factors like improper laundering. It was only after an outside dermatologist intervened that scabies was correctly identified, prompting prison-wide treatment efforts. However, these efforts were delayed and, in some cases, inadequate, resulting in prolonged suffering for the affected inmates.After their experiences, the four women filed suit in the United States District Court for the Eastern District of Michigan against multiple defendants, including high-level Michigan Department of Corrections officials and Wayne State University medical officers, alleging Eighth Amendment violations and state-law negligence. The district court found that the women’s complaint plausibly alleged “clearly established” Eighth Amendment violations by all defendants and denied the officials’ request for qualified immunity. The court also rejected a claim of state-law immunity, finding that the officials could be the proximate cause of the inmates’ injuries under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denials. The Sixth Circuit held that existing precedent did not “clearly establish” that the non-treating prison officials’ reliance on contracted medical providers was so unreasonable as to violate the Eighth Amendment. Thus, it reversed the district court’s denial of qualified immunity on the federal damages claims. However, the appellate court affirmed the denial of state-law immunity, finding the plaintiffs adequately pleaded proximate cause under Michigan law. The case was remanded for further proceedings consistent with these holdings. View "Machelle Pearson v. MDOC" on Justia Law

The case concerns the suspension of a driver’s license by the California Department of Motor Vehicles (DMV) after the driver, stopped for erratic driving and suspected of being under the influence of alcohol, refused a chemical test when properly advised of the consequences. At the administrative hearing regarding his suspension, the DMV’s hearing officer introduced evidence, asked clarifying questions, and ruled on objections, all while stating she was acting as a neutral factfinder rather than as an advocate for the DMV. The driver argued that the hearing officer’s dual roles violated his due process rights by making her both a prosecutor and adjudicator.After the DMV sustained the license suspension, the driver petitioned the Superior Court of Alameda County for a writ of mandate, claiming that the hearing officer functioned as both advocate and judge, creating an unconstitutional risk of bias. The trial court denied the petition, finding that the DMV’s current policy required hearing officers to act only as neutral decisionmakers and that no due process violation occurred.The California Court of Appeal, First Appellate District, Division Five, reviewed the denial. The court clarified that due process requires an impartial adjudicator but does not prohibit the same person from developing the evidence and making a decision in an administrative setting, so long as there is no disqualifying interest or extraordinary evidence of bias. The court held that the DMV’s current structure does not violate due process, as hearing officers are presumed impartial and their actions in presenting evidence do not turn them into advocates. The judgment of the trial court was affirmed. The court expressly declined to follow recent decisions adopting an “appearance of bias” standard and reinforced that only an actual, constitutionally intolerable risk of bias triggers a due process violation. View "Chi v. Dept. of Motor Vehicles" on Justia Law

A California-based company that produces lab-grown chicken sought to distribute and sell its product in Florida. After the company received federal approval from the USDA and FDA to market its lab-grown chicken, Florida enacted SB 1084, a law banning the manufacture, sale, and distribution of all lab-grown meat within the state. The company had previously held tasting events and developed business relationships in Florida but had no plans to manufacture its product there.Following the enactment of SB 1084, the company filed suit in the U.S. District Court for the Northern District of Florida against state officials, seeking declaratory and injunctive relief. The company argued that the federal Poultry Products Inspection Act (PPIA) preempted Florida’s ban, claiming the state’s law imposed “additional or different” ingredient or facilities requirements in violation of the PPIA. The district court denied the company’s motion for a preliminary injunction, finding the company unlikely to succeed on its preemption claims because SB 1084 did not regulate the company’s ingredients, premises, facilities, or operations. The court also addressed standing and procedural questions, ultimately dismissing the preemption claims after the company amended its complaint.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the filing of an amended complaint or the district court’s dismissal order rendered the appeal moot and whether the company could challenge the Florida law as preempted. The Eleventh Circuit held the appeal was not moot and that the company could bring a preemption action in equity. However, the court concluded the company was unlikely to succeed on the merits. The court held that Florida’s ban did not impose ingredient or facilities requirements preempted by the PPIA, as it simply banned the product’s sale and manufacture. Therefore, the district court’s denial of a preliminary injunction was affirmed. View "Upside Foods Inc v. Commissioner, Florida Department of Agriculture" on Justia Law

Intuit, Inc., the seller of TurboTax tax-preparation software, advertised its “Free Edition” as available at no cost for “simple tax returns.” However, the majority of taxpayers did not qualify due to various exclusions, and those individuals were prompted during the tax preparation process to upgrade to paid products. The Federal Trade Commission (FTC) brought an administrative complaint in 2022, alleging that these advertisements were deceptive under Section 5 of the FTC Act. After an initial federal court suit for a preliminary injunction was denied, the FTC pursued the matter through its internal adjudicative process instead.An Administrative Law Judge (ALJ) concluded that Intuit’s advertisements were likely to mislead a significant minority of consumers. The FTC Commissioners affirmed this decision, issuing a broad cease-and-desist order that barred Intuit from advertising “any goods or services” as free unless it met stringent requirements. This order was not limited to tax-preparation products. Intuit petitioned the United States Court of Appeals for the Fifth Circuit for review, asserting, among other arguments, that the FTC’s adjudication of deceptive advertising claims through an ALJ, rather than an Article III court, was unconstitutional.The United States Court of Appeals for the Fifth Circuit held that deceptive advertising claims under Section 5 of the FTC Act are akin to traditional actions at law or equity, such as fraud and deceit, and thus involve private rights. According to recent Supreme Court precedent in SEC v. Jarkesy, such claims must be adjudicated in Article III courts, not by agency ALJs. The Fifth Circuit granted Intuit’s petition, vacated the FTC’s order, and remanded the case to the agency for further proceedings consistent with its holding. View "Intuit v. Federal Trade Commission" on Justia Law