Justia Government & Administrative Law Opinion Summaries

The case involves a dispute between a taxpayers' association and a water district over the imposition of groundwater replenishment charges. The taxpayers' association alleged that the water district's charges violated constitutional provisions and unfairly benefited large agricultural businesses. The association sought a writ of mandate to stop the collection of these charges and to vacate the resolutions imposing them. They also claimed conversion, civil conspiracy, aiding and abetting, and violations of the Unfair Competition Law (UCL) against the water district's board members, general manager, and consulting firms.The Superior Court of Riverside County denied the defendants' anti-SLAPP motion, which sought to strike several causes of action on the grounds that they arose from protected activities. The court found that the public interest exemption to the anti-SLAPP statute applied. Additionally, the court sustained the defendants' demurrer to the first amended petition and complaint, finding the claims time-barred under the validation statutes. The court also awarded over $180,000 in attorney's fees to the plaintiffs, deeming the anti-SLAPP motion frivolous.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the public interest exemption did not apply because the relief sought could only be provided by the water district, not the individual defendants. The court found that the anti-SLAPP motion should have been granted for most causes of action, except for conversion and the writ of mandate against the general manager. Consequently, the fee award was reversed. The court also affirmed the demurrer ruling, as the claims against the individual defendants were not legally sufficient. The case was remanded for further proceedings consistent with these findings. View "Howard Jarvis Taxpayers Assn. v. Powell" on Justia Law

Adam Richardson, a citizen and taxpayer, petitioned the Supreme Court of Florida for writs of quo warranto and mandamus, alleging that the Governor, Attorney General, and Secretary of the Florida Agency for Health Care Administration (AHCA) violated section 104.31, Florida Statutes, by advocating against a proposed constitutional amendment (Amendment 4) related to abortion rights. Richardson claimed that their actions, including statements on an AHCA webpage and social media, as well as participation in a public call and opinion piece, unlawfully interfered with the vote on Amendment 4.The lower courts did not review this case as it was directly brought to the Supreme Court of Florida. Richardson argued that the respondents' actions violated a statute limiting political activities of state officers and employees, which he believed should be enforced through extraordinary writs.The Supreme Court of Florida denied the petition. The court held that the writ of quo warranto is traditionally used to test the right of a person to hold an office or exercise a state-derived power, not to compel criminal prosecution or enable private enforcement of a criminal statute. The court found that Richardson's grievances were more about the merits of the respondents' actions rather than their authority to act. Additionally, the court denied the writ of mandamus, stating that Richardson did not establish a clear legal right or an indisputable legal duty on the part of the respondents, nor did he show that there was no other adequate remedy available. The court concluded that no further relief was required to complete the exercise of its jurisdiction and denied the petition without permitting a rehearing. View "Richardson v. Secretary, Florida Agency for Health Care Administration" on Justia Law

The case involves a challenge to Montana House Bill 702 (HB 702), which prohibits discrimination based on vaccination status. Plaintiffs, including health care providers and individuals with compromised immune systems, argued that HB 702 is preempted by the Americans with Disabilities Act (ADA) and the Occupational Health and Safety Act (OSH Act) and violates the Equal Protection Clause of the Fourteenth Amendment. They sought to invalidate HB 702 in all health care settings, claiming it prevents employers from knowing employees' vaccination status, thus hindering ADA-required accommodations and OSH Act compliance.The United States District Court for the District of Montana ruled in favor of the plaintiffs, holding that HB 702 is preempted by the ADA and the OSH Act and violates the Equal Protection Clause. The court issued a permanent injunction against the enforcement of HB 702 in health care settings, reasoning that the law conflicts with federal requirements for reasonable accommodations and workplace safety.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision and vacated the injunction. The Ninth Circuit held that neither the ADA nor the OSH Act facially preempts HB 702 in health care settings. The court found that the plaintiffs did not demonstrate a genuine conflict between HB 702 and the ADA or OSH Act in any specific case, much less in all health care settings. The court also held that HB 702 does not violate the Equal Protection Clause, as the classification and differential treatment of facilities could rationally reflect Montana's interest in balancing personal privacy and public health.The Ninth Circuit reserved judgment on whether the ADA and the OSH Act could preempt HB 702 on a narrower, as-applied basis in future cases. The court deemed moot the portion of the district court's order related to interim CMS regulations, as those regulations have been rescinded. The court concluded that HB 702 is not facially invalid under the ADA, OSH Act, or Equal Protection Clause and vacated the district court's injunction in full. View "MONTANA MEDICAL ASSOCIATION V. KNUDSEN" on Justia Law

A group called Moms for Liberty, along with several individual members, filed a lawsuit against Brevard Public Schools and members of the Brevard County School Board. The plaintiffs claimed that their speech was unconstitutionally restricted at school board meetings. They argued that the Board's policies prohibiting "abusive," "personally directed," and "obscene" speech were unconstitutional. The plaintiffs sought declaratory and injunctive relief, as well as nominal damages.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Board. The district court concluded that the plaintiffs lacked standing because they could not show an actual or imminent injury. It also held that the Board's policies did not objectively chill the plaintiffs' protected speech. Despite finding no standing, the district court went on to rule that the Board's policies were constitutional.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The Eleventh Circuit found that the plaintiffs had standing to seek both retrospective and prospective relief. The court held that the Board's policy on "abusive" speech was unconstitutional because it was viewpoint-based and prohibited offensive speech. The policy on "personally directed" speech was also found to be unreasonable and inconsistently enforced, making it unconstitutional. Lastly, the court ruled that the prohibition on "obscene" speech was unreasonably applied to restrict protected speech, particularly when it involved reading from books available in school libraries. The case was remanded for further proceedings consistent with the Eleventh Circuit's opinion. View "Moms for Liberty v. Brevard Public Schools" on Justia Law

Plaintiffs, including Free Speech Coalition, Inc. and others, sought to prevent Utah officials from enforcing a law requiring age verification for online pornography. They argued that the law violated the First Amendment and other constitutional rights. The law allows private parties to sue commercial entities that fail to verify users' ages. Plaintiffs claimed this law imposed unconstitutional restrictions on free speech and sought declaratory and injunctive relief against the Attorney General of Utah and the Commissioner of the Utah Department of Public Safety.The United States District Court for the District of Utah dismissed the case, ruling that the defendants were entitled to Eleventh Amendment immunity. The court found that the defendants did not enforce or give effect to the law, thus the Ex parte Young exception to sovereign immunity did not apply. The district court also noted that the Commissioner’s oversight of a mobile driver's license program did not constitute enforcement of the law, as the program did not yet provide for online age verification.The United States Court of Appeals for the Tenth Circuit affirmed the district court's dismissal. The appellate court agreed that neither the Attorney General nor the Commissioner enforced or gave effect to the law. The court held that the Ex parte Young exception did not apply because the law placed enforcement authority with private individuals, not state officials. The court also found that the Commissioner’s management of the mobile driver's license program was too attenuated to constitute enforcement of the law. Consequently, the court affirmed the dismissal of the plaintiffs' complaint based on Eleventh Amendment immunity. View "Free Speech Coalition v. Anderson" on Justia Law

Crusader Gun Group, L.L.C. applied for a Federal Firearms License (FFL) in November 2020, with Alan Aronstein identified as the president and responsible person. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) denied the application, citing Aronstein's history of willfully violating federal firearms laws through his previous roles in other firearms businesses. These violations included over 6,000 recordkeeping errors, failure to report the theft or loss of firearms, and possession of unlawful machine guns. Crusader requested a hearing, but the ATF upheld its decision, leading Crusader to seek judicial review.The United States District Court for the Southern District of Texas reviewed the case and granted summary judgment in favor of the ATF. The court found that the ATF was authorized to deny the application based on Aronstein's willful violations of federal firearms laws. Crusader's cross-motion for summary judgment was denied, prompting an appeal to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court's decision. The court held that the ATF was authorized to deny Crusader's FFL application under 18 U.S.C. § 923(d)(1)(C) because Aronstein, as the responsible person, had willfully violated federal firearms laws. The court also rejected Crusader's due process claims, noting that adequate procedural safeguards were in place, including notice, a hearing, and the opportunity for judicial review. Additionally, the court found no abuse of discretion in the district court's decision to stay discovery, as the administrative record was sufficient for summary judgment. The court concluded that the ATF's denial of the FFL application was lawful and supported by substantial evidence. View "Crusader Gun Group v. James" on Justia Law

Steve Winder became suicidal after discovering Facebook messages between his wife and her ex-husband. His wife, Latrisha, who was out of state, called her mother, Lou Anne, and the Young County Sheriff’s Department for a welfare check after Steve sent pictures of himself holding a gun to his head. Deputy Joshua Gallardo arrived at the scene, and after hearing Steve shout from within, opened the front door. Lou Anne indicated that Steve was armed. Deputy Gallardo then fatally shot Steve after ordering him to put the gun down.The United States District Court for the Northern District of Texas dismissed the case at the 12(b)(6) stage. The court found that Steve’s suicidality and possession of a gun created exigent circumstances excusing the need for a warrant. It also ruled that an objectively reasonable officer in Deputy Gallardo’s position would not need to wait for Steve to point the gun at him before using deadly force, thus defeating the excessive force claim. Additionally, the court found no underlying constitutional violation to support claims for supervisory or Monell liability and ruled that Title II of the ADA does not support claims where police officers face exigent circumstances.The United States Court of Appeals for the Fifth Circuit affirmed the District Court’s dismissal. The appellate court held that the exigent circumstances justified the warrantless entry and that Deputy Gallardo’s use of deadly force was reasonable under the circumstances. The court also found no basis for supervisory or Monell liability due to the absence of an underlying constitutional violation. Lastly, the court ruled that the ADA claims were foreclosed by the exigent circumstances and that there was no evidence that Steve was discriminated against by reason of his disability. View "Winder v. Gallardo" on Justia Law

The Tuscaloosa City Council passed an ordinance limiting the maximum occupancy of certain restaurants, affecting a sports bar owned by CMB Holdings Group. The ordinance required establishments with restaurant liquor licenses to maintain occupancy limits based on their configuration as restaurants, not as bars or entertainment venues. This change reduced the sports bar's maximum occupancy from 519 to 287, negatively impacting its revenue. CMB Holdings Group sued the City of Tuscaloosa, the mayor, city council members, and the fire marshal, alleging racial discrimination and other claims.The Tuscaloosa Circuit Court dismissed most of CMB's claims, including those for money damages against the City and personal-capacity claims against the mayor and councilors due to legislative immunity. The court also dismissed claims for procedural and substantive due process, equal protection, and others, leaving only claims for declaratory and injunctive relief under the Alabama Constitution's Contracts Clause. CMB requested the court to alter or amend its judgment or certify it as final for appeal purposes. The court denied the request to alter or amend but granted the Rule 54(b) certification, allowing CMB to appeal the dismissed claims.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper. The court found that the adjudicated and unadjudicated claims were closely intertwined, particularly regarding whether the ordinance affected vested rights or mere privileges and whether it served a legitimate public interest. The court concluded that separate adjudication could lead to inconsistent results and dismissed the appeal for lack of a final judgment. View "CMB Holdings Groupv. City of Tuscaloosa" on Justia Law

The case involves the District Attorney (DA) of Philadelphia, who challenged articles of impeachment passed by the Pennsylvania House of Representatives. The articles were transmitted to the Senate on the last day of the 206th General Assembly session. The DA argued that the articles became null and void upon the session's expiration, and the new Senate could not conduct a trial based on them.The Commonwealth Court initially denied the DA's request for summary relief, ruling that the impeachment articles did not expire with the session's end. The court also found that the DA, as a local official, could be impeached under the Pennsylvania Constitution. However, the court agreed with the DA that some articles of impeachment did not allege conduct amounting to "misbehavior in office" and that certain articles intruded on the judiciary's exclusive authority to govern attorney conduct.The Supreme Court of Pennsylvania reviewed the case. The court first addressed the justiciability of the issue, concluding that it had the authority to determine whether the impeachment articles expired with the session's end. The court emphasized that the Constitution must be read as an integrated whole, and the General Assembly's powers, including impeachment, are limited to the duration of its session.The court held that the articles of impeachment became null and void upon the expiration of the 206th General Assembly session. Consequently, the Senate of the 207th General Assembly could not conduct a trial based on those articles. The court reversed the Commonwealth Court's order denying the DA's request for summary relief on this issue. View "Krasner v. Ward" on Justia Law

Two commercial fishermen, Raymond Lofstad and Gus Lovgren, challenged the constitutionality of the appointment process for members of the Mid-Atlantic Fishery Management Council. The Council, which oversees fisheries from New York to Virginia, had approved an amendment lowering the catch limits for certain fish species, which the Secretary of Commerce subsequently approved. The fishermen argued that the Council members, who were not appointed by the President or confirmed by the Senate, exercised significant authority and thus should be considered "Officers of the United States" under the Appointments Clause of the Constitution.The United States District Court for the District of New Jersey ruled against the fishermen, holding that the Council members did not exercise significant authority and were therefore not officers. The court granted summary judgment in favor of the government, reasoning that the Council's role was merely advisory and did not involve significant authority.The United States Court of Appeals for the Third Circuit reviewed the case de novo and found that the Council members did exercise significant authority, particularly through their power to veto certain actions by the Secretary of Commerce. The court held that these veto powers made the Council members principal officers who should have been appointed by the President and confirmed by the Senate. To remedy the constitutional violation, the court severed the Council's pocket-veto powers, reducing the members to mere employees who do not require such appointments. The court reversed the District Court's summary judgment for the government and rendered judgment for the fishermen. View "Lofstad v. Secretary United States Department of Commerce" on Justia Law