Justia Government & Administrative Law Opinion Summaries

In this case, the Supreme Court of the State of Arizona addressed two key issues related to the City of Scottsdale's decision not to award a license to operate competitive youth swimming programs at its public aquatic centers to Neptune Swimming Foundation, despite Neptune submitting a financially lucrative proposal through a request-for-proposal (RFP) process. Instead, the City chose to extend an existing license agreement with Scottsdale Aquatic Club (SAC), which had operated programs at the centers for over fifty years.The court first addressed whether a bid from a higher bidder should be considered when determining whether the City violated the Arizona Constitution's Gift Clause, which prohibits public entities from making donations or grants to any individual, association, or corporation. The court held that the higher bid in the RFP process was relevant, but not conclusive, in determining the fair market value of the license. A public entity does not necessarily violate the Gift Clause by choosing a less profitable arrangement. The court affirmed the lower court's summary judgment in favor of the City on this issue.The second issue was whether the City abused its discretion by failing to follow its own procurement process rules when it canceled the RFP and extended SAC's existing license agreement. The court found that there were material factual disputes about whether the City violated its own procurement process, which should have precluded summary judgment for the City on this issue. The court therefore reversed the lower court's summary judgment in favor of the City on this issue and remanded the case for further proceedings. View "NEPTUNE SWIMMING FOUNDATION v CITY OF SCOTTSDALE" on Justia Law

In 2022, Oregon voters approved Ballot Measure 113, amending the state constitution to disqualify any state legislator who accumulates 10 or more unexcused absences during a legislative session from holding office "for the term following the election after the member’s current term is completed." The Secretary of State interpreted this to mean that the disqualification applies to a legislator’s immediate next term. However, a group of legislators challenged this interpretation, arguing that the disqualification should apply one term later.The Supreme Court of the State of Oregon held that the measure's disqualification applies to the legislator’s immediate next term of office. The Court found that the text of the amendment was capable of supporting the Secretary's interpretation. This interpretation was also supported by the ballot title and the voters’ pamphlet, which repeatedly described the disqualification as occurring immediately following the legislator’s current term. The Court concluded that voters would have understood the amendment in light of these materials. Therefore, the Court upheld the Secretary's rules implementing the amendment. View "Knopp v. Griffin-Valade" on Justia Law

Four Iranian nationals, who had previously completed mandatory military service in Iran's Islamic Revolutionary Guard Corps (IRGC), were denied visas to enter the United States. Their family members, three U.S. citizens and one lawful permanent resident, filed a suit against the President and several federal officials responsible for visa applications. They alleged that the defendants unlawfully deprived visa applicants the opportunity to establish eligibility for terrorism-related inadmissibility grounds (TRIG) exemptions, violating their rights under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The district court dismissed the case under the doctrine of consular nonreviewability, which bars judicial review of consular decisions. The Plaintiffs appealed, and the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the doctrine of consular nonreviewability applied, and that the plaintiffs failed to show any evidence of bad faith that could overcome this doctrine. The court also held that the applicants were not entitled to any more explanation for their visa denials than the citation to the section of the law on which the denial was based. View "Pak v. Biden" on Justia Law

In the case of City of St. Louis and Heather Taylor (“Appellants”) versus State of Missouri (“State”), the Supreme Court of Missouri analyzed Senate Bill No. 26 (“SB 26”) that was challenged for being unconstitutional. SB 26, introduced in December 2020 and signed into law in July 2021, contained 88 sections related to public safety, including procedures for imposing discipline on law enforcement officers and provisions for the offense of “unlawful traffic interference.”Appellants argued that SB 26 violated the Missouri Constitution on several grounds, including that it violated the original-purpose and single-subject rules, that it created an unfunded mandate, that it imposed additional duties on officers and employees of a constitutional charter city, that it used public funds for private purposes, and that it created unequal treatment between law enforcement officers and other city employees.The Supreme Court of Missouri found that the City had sufficiently pleaded the elements of a Hancock Amendment violation, which prohibits the state from requiring new or expanded activities by counties and other political subdivisions without full state financing. Therefore, the circuit court's judgment was reversed on this point and the case was remanded for further proceedings.However, the court affirmed the judgment with respect to Appellants' other points. It found that SB 26 had the same purpose as enacted as introduced, did not impose new duties on city employees or allocate funds for public purposes, and had a rational basis for treating law enforcement officers differently from other city employees. The court also found that SB 26 did not violate the original-purpose and single-subject rules, did not impose additional duties on officers and employees of a constitutional charter city, did not use public funds for private purposes, and did not create unequal treatment between law enforcement officers and other city employees. View "City of St. Louis v. State" on Justia Law

In this case, the City of Laramie, Wyoming, sued the University of Wyoming and its Board of Trustees, challenging the drilling and operation of certain water wells. The city argued that the university was in violation of a 1965 deed covenant prohibiting the drilling of one of the wells and was also in violation of a city ordinance. The city also claimed that legislation exempting the university from this city ordinance was unconstitutional. The district court dismissed some of the city's claims and granted summary judgment in favor of the university on the remaining claims. The Supreme Court of Wyoming affirmed the lower court's decision. The court held that the university was protected by sovereign immunity from the city's attempts to enforce the deed covenant. It also held that the state law exempting the university from the city ordinance was constitutional. The court further noted that the law precluded the city from enforcing its ordinance against the university. View "City of Laramie, Wyoming v. University of Wyoming" on Justia Law

In a case before the Supreme Court of New Hampshire, the plaintiffs, two police officers injured in a shooting, filed a suit against Chester Arms, LLC (the seller of the firearm used in the shooting), and the New Hampshire Department of Safety (DOS) (which conducted the background check for the sale of the firearm). The suit accused Chester Arms of negligent entrustment and DOS of negligent entrustment and negligence per se. The trial court granted summary judgment in favor of both defendants on the basis of immunity under state law. The court of appeals affirmed the lower court's decision.The court of appeals found that the state law barring lawsuits against firearms manufacturers and sellers for damages resulting from the criminal or unlawful use of their products by a third party was constitutional and not preempted by federal law. The court found that the law was designed to safeguard citizens' fundamental right to bear arms by limiting suits against the firearms industry, thereby protecting its solvency and ensuring law-abiding citizens have access to firearms. The court also found that the law did not violate the plaintiffs' constitutional right to equal protection or right to a remedy.Regarding the suit against DOS, the court found that DOS had not been negligent in its background check as the shooter was not disqualified from owning a firearm at the relevant time under federal law. Therefore, the court concluded that any alleged error in the trial court's immunity analysis was harmless as DOS was entitled to judgment as a matter of law. View "Hardy v. Chester Arms, LLC" on Justia Law

In this case, the Idaho State Athletic Commission and the Idaho Division of Occupational and Professional Licenses sought a declaratory ruling that provisions of the Idaho Administrative Procedure Act (APA) requiring legislative approval of pending administrative fee rules violated the Idaho Constitution. They also sought a Writ of Mandamus directing the Office of the Administrative Rules Coordinator to publish the Athletic Commission’s 2022 administrative rules in the Idaho Administrative Code. The Idaho Supreme Court held that it had jurisdiction to consider the case, but dismissed the petition for a declaration of unconstitutionality and denied the petition for a Writ of Mandamus. The court concluded that the APA requirement for legislative approval of pending administrative rules did not violate the Idaho Constitution's separation of powers, enactment, presentment, or administrative rules provisions. In reaching this conclusion, the court emphasized that administrative rulemaking authority was a legislative delegation, not a constitutional power, and that the legislature was free to modify the process by which administrative rules were enacted. View "Idaho State Athletic Commission v. Office of the Administrative Rules Coordinator" on Justia Law

In South Carolina, two hospitals, Walterboro Community Hospital and Trident Medical Center, appealed an Administrative Law Court (ALC) order which approved the certificate of need (CON) for the Medical University Hospital Authority (MUHA). MUHA had applied for a CON to construct a new general hospital in Berkeley County to address capacity issues at its existing hospital in Charleston. The appellant hospitals raised four issues against ALC's decision: 1) the ALC's dismissal of certain errors in the review by the South Carolina Department of Health and Environmental Control (DHEC), 2) a misinterpretation of the State Health Plan by the ALC, 3) the ALC's approval of MUHA's application conditional on the closure of a freestanding emergency department planned by MUHA, and 4) the appeal bond required by South Carolina law is unconstitutional.The Supreme Court of South Carolina affirmed the ALC's decision and held that despite errors in DHEC's review process and decision, the ALC's de novo review rendered these errors harmless. The court also agreed with ALC's interpretation of the State Health Plan and found no issue in the ALC's condition of approval. The court further held that the appeal bond requirement was not unconstitutional, as the appellant hospitals were statutory affected persons and there was a rational basis for different treatment for a party opposing an approved CON and a party appealing the denial of its own CON application. However, the court did instruct that the appeal bond be voided and returned to Trident Medical Center. View "Walterboro Comm Hospital v. SCDHEC" on Justia Law

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