Justia Government & Administrative Law Opinion Summaries

Articles Posted in Constitutional Law
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Several members of the public requested records from the Seattle Police Department (SPD) regarding officers who attended the January 6, 2021, rally in Washington, DC. The officers involved filed a lawsuit to prevent the release of their identities, arguing that their identities should be exempt from disclosure based on statutory and constitutional privacy rights. They sought a preliminary injunction to prevent the release of their identities within those public records.The King County Superior Court denied the officers' motion for a preliminary injunction, determining that the officers failed to show that the information in the public records was likely exempt from disclosure. The court also denied the officers' motion to proceed under pseudonyms. The officers appealed, and the Court of Appeals reversed the denial of the preliminary injunction, concluding that the First Amendment prohibited the disclosure of the officers' identities. The Court of Appeals did not evaluate whether the disclosure would violate the officers' statutory right to privacy under the Public Records Act (PRA).The Supreme Court of the State of Washington reviewed the case and held that the officers did not demonstrate a likelihood of success on the merits that their identities were exempt based on either a statutory or constitutional right to privacy. The court concluded that the officers did not have a privacy interest in their identities as public employees who attended a highly publicized event. The court also held that the officers did not show a need to litigate under pseudonyms. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "John Does v. Seattle Police Dep't" on Justia Law

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In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law

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Joseph Rivera's driver's license was permanently revoked by New York authorities after he was convicted of three alcohol-related driving offenses between 2000 and 2010. Rivera moved to Alaska in 2011 but did not apply for an Alaska driver's license until 2021. His application was denied by the Alaska Department of Motor Vehicles (DMV) because his license was still revoked in New York. Rivera sought reinstatement of his driving privileges in New York, but his requests were denied. He then requested an administrative hearing with the Alaska DMV, which upheld the denial of his application.Rivera appealed to the Superior Court of the State of Alaska, Third Judicial District, arguing that the DMV misapplied Alaska's licensing statutes and that the statutes conflicted. The superior court affirmed the DMV's decision, rejecting Rivera's arguments.The Supreme Court of the State of Alaska reviewed the case and held that Alaska's driver’s license statutes do not conflict. The court found that the statutes operate in harmony, with the Compact providing a framework for considering out-of-state driving records and Alaska's statutes imposing additional requirements. Specifically, Alaska Statute 28.15.031(b)(1) prevents the DMV from issuing a license to anyone whose driving privileges are revoked in any jurisdiction, including out-of-state revocations. The court concluded that the DMV properly applied this statute in denying Rivera's application.The court also addressed Rivera's arguments regarding equal protection and manifest injustice, finding them unpersuasive. The court noted that Rivera had not exhausted all available appeals in New York and that the DMV's decision did not result in manifest injustice. Consequently, the Supreme Court of the State of Alaska affirmed the superior court's judgment and upheld the DMV's decision to deny Rivera's application for a driver's license. View "Rivera v. State" on Justia Law

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Tim Daniels, a commercial fisherman in Florida, challenged the constitutionality of regulations by Florida’s Fish and Wildlife Conservation Commission (FWC) that restrict where and how Florida-registered vessels can harvest Florida pompano in federal waters. Daniels argued that federal law preempts state regulations affecting fishing in federal waters and that Florida’s regulations violate the Equal Protection Clause by only restricting Florida-registered vessels.The United States District Court for the Southern District of Florida granted summary judgment for the FWC, concluding that Florida’s regulations do not violate the Privileges and Immunities Clause, the Supremacy Clause, the Commerce Clause, or the Equal Protection Clause. The court also determined that Daniels lacked standing to sue.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that Daniels has standing to sue because he faces a credible threat of prosecution under Florida’s regulations, which affects his commercial fishing activities. The court found that Daniels’s injury is directly traceable to Florida’s regulations and can be redressed by a favorable judicial decision.On the merits, the Eleventh Circuit held that the Magnuson-Stevens Fishery Conservation and Management Act does not preempt Florida’s regulations. The court reasoned that the Act allows states to regulate fishing vessels registered under their laws in federal waters when there is no federal fishery management plan or regulations in place. The court also held that Florida’s regulations do not violate the Equal Protection Clause because they are rationally related to the legitimate governmental purpose of conserving and managing pompano stock, and the regulations only apply to Florida-registered vessels, which are within the state’s jurisdiction.The Eleventh Circuit affirmed the District Court’s decision, upholding Florida’s pompano regulations. View "Daniels v. Executive Director of the Florida Fish and Wildlife Conservation Commission" on Justia Law

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Rhonda Fleming, an inmate at Federal Correctional Institution Tallahassee (FCIT), filed a pro se lawsuit against Warden Erica Strong and the United States, alleging Eighth Amendment violations due to her exposure to mold, asbestos, and COVID-19, which she claimed caused severe health issues. Fleming sought injunctive relief and damages under Bivens and the Federal Tort Claims Act (FTCA). She alleged that despite her complaints, the prison officials, including Warden Strong, failed to address the hazardous conditions, leading to her contracting COVID-19 twice and requiring hospitalization.The United States District Court for the Northern District of Florida partially granted and partially denied the defendants' motion to dismiss. The magistrate judge recommended dismissing most of Fleming's claims, including all claims against Strong, citing that Bivens did not provide a remedy for her Eighth Amendment claim. However, the district court disagreed, finding that Fleming's Eighth Amendment claim was similar to a previously recognized Bivens claim and allowed it to proceed. The district court did not address the issue of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court had to determine whether it had jurisdiction to hear an interlocutory appeal from the district court's order recognizing a Bivens cause of action. The Eleventh Circuit joined four other circuits in holding that the collateral-order doctrine does not extend to Bivens-extension orders that do not address qualified immunity. The court emphasized that qualified immunity adequately protects government officials from the burdens of litigation and that separation-of-powers concerns with Bivens extensions do not justify immediate appeal. Consequently, the Eleventh Circuit dismissed the appeal for lack of jurisdiction. View "Fleming v. FCI Tallahassee Warden" on Justia Law

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The case involves a proposed charter amendment in Baltimore City, known as the Baby Bonus Amendment, which would mandate a one-time payment of at least $1,000 to every eligible city resident upon the birth or adoption of a child. The Maryland Child Alliance, Inc. sponsored the petition for this amendment, which was certified by the Baltimore City Board of Elections for inclusion on the ballot for the November 2024 Presidential General Election.The Mayor and City Council of Baltimore, along with other city officials, filed a lawsuit in the Circuit Court for Baltimore City against the Baltimore City Board of Elections and the State Board of Elections, seeking judicial review, a writ of mandamus, declaratory judgment, and an injunction to prevent the Baby Bonus Amendment from being placed on the ballot. The circuit court granted the City’s motion for summary judgment, declaring the Baby Bonus Amendment unconstitutional as it violated Article XI-A, § 3 of the Maryland Constitution by removing meaningful discretion from the City over an area within its legislative purview and being legislative in nature rather than proper charter material.The Supreme Court of Maryland reviewed the case and affirmed the circuit court’s decision. The Court held that the Baby Bonus Amendment did not concern the form or structure of government and encroached upon the City’s police or general welfare powers, thus violating Article XI-A, § 3 of the Maryland Constitution. The Court also declined to sever the mandatory payment provision from the amendment, concluding that the dominant purpose of the amendment would not be achieved without the $1,000 payment provision, which abrogated the City’s law-making authority in violation of the Constitution of Maryland. View "Baltimore City Board of Elections v. Mayor and City Council of Baltimore" on Justia Law

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Christopher Hamilton was convicted of federal felony possession of child pornography. After a federal district court terminated his federal sex offender registration requirement, the California Attorney General notified him of his lifetime obligation to register under California law, pursuant to Penal Code section 290.005(a). The Attorney General determined that the state law equivalent of Hamilton’s federal offense required lifetime registration, placing him in the highest tier of California’s three-tier scheme.Hamilton petitioned the Superior Court of Los Angeles County to terminate his state registration requirement. The Superior Court denied his petition and a subsequent amended motion. Hamilton appealed the denials, arguing violations of equal protection and due process.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the Attorney General’s classification of Hamilton’s offense as a felony with a lifetime registration requirement did not violate equal protection. The court reasoned that the federal offense’s classification as a felony, based on custodial exposure, justified the equivalent state offense’s classification as a felony. Additionally, the court found that the federal offense’s requirement of interstate or foreign commerce provided a rational basis for the different treatment.The court also rejected Hamilton’s due process challenge, concluding that he received notice and had opportunities to contest his tier designation through his petition and amended motion. Lastly, the court dismissed Hamilton’s vagueness challenge, finding that the term “equivalent” in section 290.005(a) was sufficiently clear when considered in context with other statutory provisions.The Court of Appeal affirmed the Superior Court’s orders denying Hamilton’s petition and amended motion. View "People v. Hamilton" on Justia Law

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In 2022, the Georgia General Assembly enacted House Bill 839 (HB 839), which incorporated the City of Mableton within unincorporated Cobb County and provided for the creation of one or more community improvement districts (CIDs) within Mableton. Deidre White and other residents of Cobb County challenged the constitutionality of HB 839, arguing that it violated the "Single Subject Rule" of the Georgia Constitution by creating more than one unit of government, specifically Mableton and the CIDs.The trial court dismissed the complaint for failure to state a claim upon which relief could be granted. The court found that HB 839 did not violate the Single Subject Rule, as the creation of CIDs within Mableton was germane to the overall objective of incorporating the city. The Appellants then appealed this decision.The Supreme Court of Georgia reviewed the case and affirmed the trial court's dismissal. The court held that HB 839 did not violate the Single Subject Rule because the creation of CIDs within Mableton had a logical and natural connection to the incorporation of the city. The court also rejected the argument that the ballot question for HB 839 contravened the precedent set in Rea v. City of LaFayette, as the creation of CIDs was related to the single objective of establishing Mableton. Thus, the court concluded that HB 839 was constitutional and upheld the trial court's decision. View "WHITE v. CITY OF MABLETON" on Justia Law

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Plaintiffs, a class of individuals, filed mortgage foreclosure complaints in Illinois circuit courts and paid "add-on" filing fees mandated by section 15-1504.1 of the Code of Civil Procedure. They challenged the constitutionality of these fees, asserting that the statute violated the free access clause of the Illinois Constitution. The Illinois Supreme Court previously agreed, declaring the statute unconstitutional and affirming an injunction against its enforcement.The Will County circuit court initially certified the class and granted partial summary judgment, finding the statute unconstitutional. The appellate court reversed, and the case was remanded. On remand, plaintiffs pursued a refund of the fees. The circuit court dismissed the refund claim, citing sovereign immunity, which bars claims against the State. The appellate court reversed, holding that the circuit court had jurisdiction under the officer-suit exception to sovereign immunity, which allows suits against state officials for unconstitutional actions.The Illinois Supreme Court reviewed the case and held that while the officer-suit exception allowed the circuit court to enjoin the enforcement of the unconstitutional statute, it did not apply to the refund claim. The court determined that the refund claim was a retrospective monetary award to redress a past wrong, which falls under the jurisdiction of the Court of Claims, not the circuit court. Consequently, the Illinois Supreme Court reversed the appellate court's judgment and affirmed the circuit court's dismissal of the refund claim. View "Walker v. Chasteen" on Justia Law

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Courthouse News Service, a news organization, sought remote online access to civil court records from the Circuit Court for Prince William County, Virginia, similar to the access granted to Virginia attorneys. Virginia law prohibits the clerk from providing such access to non-attorneys. Courthouse News sued, claiming this restriction violated its First Amendment and Equal Protection rights.The United States District Court for the Eastern District of Virginia dismissed Courthouse News's Equal Protection claim and granted summary judgment for the defendants on the First Amendment claims. The court found the restrictions to be content-neutral time, place, and manner regulations justified by the state's interests in the orderly administration of justice and protecting sensitive personal information.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's ruling on the First Amendment and Equal Protection claims, holding that the access restriction was a content-neutral regulation narrowly tailored to serve significant governmental interests. The court found that the restriction did not violate the First Amendment as it provided ample alternative channels for accessing court records and did not burden more access than necessary. The court also concluded that the restriction did not violate the Equal Protection Clause for the same reasons it passed First Amendment scrutiny.However, the court vacated the district court's ruling on the Dissemination Restriction claim, finding that Courthouse News lacked standing to challenge it since the restriction only applied to those with remote access, which Courthouse News did not have. The case was remanded for the district court to dismiss this claim without prejudice. View "Courthouse News Service v. Smith" on Justia Law