Justia Government & Administrative Law Opinion Summaries

Several businesses involved in the cultivation, distribution, and sale of hemp products in Wyoming and elsewhere challenged a Wyoming statute, Senate Enrolled Act 24 (SEA 24), which significantly altered the state’s regulation of hemp. SEA 24 narrowed the definition of hemp to exclude synthetic substances and expanded the definition of THC to include both delta-9 and delta-8 THC, requiring that the combined concentration not exceed 0.3%. The law also added both naturally occurring and synthetic delta-8 THC to Wyoming’s Schedule I controlled substances, making it unlawful to manufacture, deliver, or possess hemp products exceeding the new THC limits or containing synthetic substances, even if such products are legal under federal law.After SEA 24 was enacted, the plaintiffs filed a preenforcement action in the United States District Court for the District of Wyoming, seeking declaratory and injunctive relief. They argued that SEA 24 was preempted by the federal 2018 Farm Bill, violated the Dormant Commerce Clause, constituted an unconstitutional regulatory taking, and was void for vagueness. The plaintiffs also sought a temporary restraining order or preliminary injunction to prevent the law from taking effect. The district court denied the motion for preliminary relief and subsequently dismissed the complaint for failure to state a claim, finding that most defendants were protected by Eleventh Amendment immunity and that the remaining claims lacked legal merit.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s dismissal. The court held that the plaintiffs lacked a substantial federal right to support their preemption claim, failed to demonstrate a Dormant Commerce Clause violation, did not establish a regulatory taking of their commercial personal property, and did not show that SEA 24 was unconstitutionally vague. The court also dismissed the appeal of the denial of preliminary relief as moot due to the dismissal of the complaint. View "Green Room v. State of Wyoming" on Justia Law

A woman with a lifelong hearing impairment obtained a commercial driver’s license (CDL) in New Jersey after receiving a federal exemption from the standard hearing requirement. This exemption allowed her to drive commercial vehicles in interstate commerce but specifically prohibited her from operating passenger vehicles or school buses. Despite this, she was mistakenly issued state endorsements permitting her to drive such vehicles and worked as a campus shuttle bus driver for about eight months. When the New Jersey Motor Vehicle Commission (NJMVC) realized the error, it revoked her passenger and school bus endorsements without providing a pre-revocation hearing.Instead of seeking review in New Jersey Superior Court, the woman filed suit in the United States District Court for the District of New Jersey. She alleged violations of Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and New Jersey’s Law Against Discrimination, as well as a procedural due process claim under 42 U.S.C. § 1983. The District Court dismissed some claims and ultimately granted summary judgment to the defendants on all remaining claims, finding she was not “qualified” for the endorsements and had no property interest in them.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The court held that the plaintiff was not a “qualified individual with a disability” under the relevant statutes because she could not meet the essential eligibility requirement of passing the hearing test for the endorsements. The court also held that, even assuming a property interest in the endorsements, due process did not require a pre-revocation hearing given the state’s strong safety interests and the availability of post-deprivation remedies. The court affirmed summary judgment for the defendants on all claims. View "Parker v. New Jersey Motor Vehicle Commission" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

In early October 2025, the President of the United States invoked his authority under 10 U.S.C. § 12406 to federalize and deploy members of the National Guard in Illinois, despite opposition from the state’s Governor. The President justified this action by citing the need to address violent assaults against federal immigration agents and property, particularly in the context of increased protests at an ICE facility in Broadview, Illinois, following the launch of “Operation Midway Blitz.” Although protests had grown in size and occasionally involved minor disruptions and isolated incidents of violence, state and local law enforcement consistently maintained control, and federal agencies reported continued success in their operations.The State of Illinois and the City of Chicago filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, challenging the federalization of the Guard. They argued that the statutory conditions for such action under § 12406 were not met, and that the move violated the Tenth Amendment and the Posse Comitatus Act. After an adversary hearing, the district court granted a temporary restraining order, finding insufficient evidence of rebellion or inability to execute federal law with regular forces, and enjoined the federalization and deployment of the Guard. The administration appealed and sought a stay of the order.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s order, applying clear error review to factual findings and de novo review to statutory interpretation. The Seventh Circuit held that the President’s decision to federalize the National Guard under § 12406 is judicially reviewable and that, even granting substantial deference to the executive, the statutory predicates for federalization were not met on the current record. The court denied the administration’s motion for a stay pending appeal as to deployment, but continued to stay the portion of the order enjoining federalization. View "Illinois v. Trump" on Justia Law

A flight attendant employed by an airline and represented by a labor union was terminated after sending graphic anti-abortion images and messages to the union president and posting similar content on social media. The employee, a pro-life Christian and vocal opponent of the union, had previously resigned her union membership but remained subject to union fees. The union’s leadership had participated in the Women’s March, which the employee viewed as union-sponsored support for abortion, prompting her messages. The airline investigated and concluded that while some content was offensive, only certain images violated company policy. The employee was terminated for violating social media, bullying, and harassment policies.Following termination, the employee filed a grievance, which the union represented. The airline offered reinstatement contingent on a last-chance agreement, which the employee declined, leading to arbitration. The arbitrator found just cause for termination. The employee then sued both the airline and the union in the United States District Court for the Northern District of Texas, alleging violations of Title VII and the Railway Labor Act (RLA), among other claims. The district court dismissed some claims, allowed others to proceed, and after a jury trial, found in favor of the employee on several Title VII and RLA claims. The court awarded reinstatement, backpay, and issued a broad permanent injunction against the airline and union, later holding the airline in contempt for its compliance with the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the judgment for the employee on her belief-based Title VII and RLA retaliation claims against the airline, remanding with instructions to enter judgment for the airline on those claims. The court affirmed the judgment against the airline on practice-based Title VII claims and affirmed all claims against the union. The court vacated the permanent injunction and contempt sanction, remanding for further proceedings, and granted the employee’s motion to remand appellate attorney’s fees to the district court. View "Carter v. Transport Workers Union of America Local 556" on Justia Law

In this case, a group consisting of an alumni association and several descendants of Serranus Clinton Hastings challenged the enactment of Assembly Bill 1936, which changed the name of “Hastings College of the Law” to “College of the Law, San Francisco” and eliminated a statutory requirement that a seat on the College’s board of directors be reserved for an heir or representative of S.C. Hastings. The plaintiffs argued that the original 1878 Act establishing the College constituted a binding contract between the State and S.C. Hastings and his descendants, and that the new legislation violated constitutional protections, including the Contract Clauses, the prohibition on bills of attainder and ex post facto laws, and the California Constitution’s provision regarding collegiate freedom.The Superior Court of the City and County of San Francisco sustained the defendants’ demurrer without leave to amend, finding that the plaintiffs failed to establish that the 1878 Act was a contract rather than an exercise of legislative power. The court also determined that Assembly Bill 1936 did not constitute a bill of attainder or ex post facto law, and that the changes to the College’s name and governance did not violate the California Constitution, particularly since the College’s board had requested the name change.The California Court of Appeal, First Appellate District, Division Four, reviewed the case de novo and affirmed the trial court’s judgment. The appellate court held that the State could not contract away its sovereign authority to manage a public institution, including the power to change the College’s name or governance structure. The court further concluded that Assembly Bill 1936 was not punitive and did not violate constitutional prohibitions on bills of attainder or ex post facto laws. The court also found no violation of the California Constitution’s collegiate freedom provision, as the changes were initiated by the College’s board. The judgment in favor of the State and College defendants was affirmed. View "Hastings College Conservation Committee v. State" on Justia Law

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