Justia Government & Administrative Law Opinion Summaries

On November 14, 2020, Officer David Collier and his partner arrived at a residence in Escambia County, Florida, to serve arrest warrants on Jacob Settle and his wife. Settle was in his truck parked closely alongside the house in a dark, debris-filled backyard. When the officers approached and identified themselves, Settle refused to exit the vehicle. After Collier threatened to break the truck’s windows, Settle started the engine and shifted the transmission into gear. Collier, believing he and his partner were in imminent danger due to his proximity to the truck, fired his gun into the vehicle, fatally wounding Settle. Settle’s estate sued Collier for excessive force under the Fourth Amendment and for battery under Florida law.The United States District Court for the Northern District of Florida considered Collier's motion for summary judgment, in which he asserted qualified immunity and state law immunity. The district court denied the motion, finding that a reasonable jury could conclude Collier violated Settle’s constitutional rights by using deadly force on a non-moving vehicle that did not pose a risk to the officers. The district court also denied state immunity for the battery claim, reasoning that a jury could find Collier acted with wanton disregard for Settle’s safety.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court held that Collier was entitled to qualified immunity, concluding that his use of deadly force was objectively reasonable because Settle’s actions—starting the engine and shifting the truck into gear while resisting arrest—could reasonably be perceived as an immediate threat. The court further held that Collier was entitled to state statutory immunity from the battery claim, as his conduct met the standards for justified use of force under Florida law. The Eleventh Circuit reversed the district court’s decision and remanded with instructions to enter judgment for Collier. View "Settle v. Collier" on Justia Law

A nonprofit research foundation affiliated with a state university entered into a memorandum of understanding (MOU) with the university in 2007, becoming a statutorily regulated direct-support organization (DSO). The MOU provided that the foundation’s board would include two appointees from the university but was otherwise silent on board approval and on budget approval processes. In 2018, the Florida Legislature enacted a law requiring all DSO board appointments to be approved by the university’s board of trustees. Around the same time, a regulation by the Board of Governors (BOG) required university boards of trustees to approve DSO budgets. The foundation challenged these requirements, arguing that they impaired its contractual rights under the MOU.The Circuit Court conducted a trial and found that the MOU limited the university’s involvement to only the two appointees and that the statutory board approval requirement impaired the MOU. It concluded that the university failed to show a significant and legitimate public purpose for the statute. However, regarding the budget approval dispute, the court held that the MOU did not address budget approval, so there was no contractual impairment. The Fourth District Court of Appeal affirmed both findings, concluding that the statutory board approval requirement rewrote the parties’ contract, while the regulation on budget approval did not impair the MOU.The Supreme Court of Florida reviewed the case. It held that the MOU only addressed the university’s power to appoint two board members and was silent on approval of other appointments or on budget approval. Therefore, the statutory and regulatory changes did not impair any specific contractual obligations. The court reversed the Fourth District’s ruling on the board appointment issue and otherwise affirmed, holding that neither the statute nor the regulation unconstitutionally impaired the MOU. View "Florida Atlantic University Board of Trustees v. Harbor Branch Oceanographic Institute Foundation, Inc." on Justia Law

Several current and former employees of the City of Chicago, including police officers and an emergency management officer, challenged the City’s COVID-19 vaccination policy. The policy, issued in October 2021, required city employees to either be vaccinated against COVID-19 or undergo regular testing and report their status through an employee portal. Religious exemptions from vaccination were available and granted to these plaintiffs, but the plaintiffs objected to having to submit their vaccination status and test results in the portal, arguing that this reporting requirement violated their constitutional and statutory rights.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, raising claims under Title VII of the Civil Rights Act of 1964, the First and Fourteenth Amendments via 42 U.S.C. § 1983, and the Illinois Religious Freedom Restoration Act (IRFRA). The district court dismissed the Third Amended Complaint for failure to state a claim. It found the Title VII claims factually implausible and concluded that the plaintiffs did not allege a religious practice conflicting with the reporting requirements. The court also held that, since the plaintiffs were granted their requested exemptions from vaccination, they could not succeed on claims based on their refusal to comply with reporting requirements.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The Seventh Circuit held that the policy’s reporting requirements were neutral and generally applicable, subject only to rational-basis review, which the policy satisfied. The court determined that the reporting and disciplinary provisions were rationally related to the City’s legitimate interest in public health and workplace safety. The court affirmed the district court’s dismissal of all constitutional, statutory, and state-law claims, finding the plaintiffs’ arguments insufficient to state a plausible claim for relief. View "Kondilis v City of Chicago" on Justia Law

The plaintiffs, all residents, property owners, and taxpayers in Johnson County, Wyoming, brought a declaratory action against the county’s Board of Commissioners and the Wyoming Department of Audit (including its Director). Their complaint alleged that the Board mismanaged county finances and violated state fiscal statutes, and that the Department failed to enforce compliance. The plaintiffs claimed that these actions caused them tangible harm as taxpayers through increased taxes and fees. Their suit included ten counts, all seeking declarations of statutory or constitutional violations and requesting judicial oversight, including a forensic audit.The District Court of Johnson County reviewed the case after the Board and the Department moved to dismiss, arguing that the plaintiffs lacked standing to sue. The district court agreed, finding that the plaintiffs had not demonstrated a sufficient personal or particularized injury, and dismissed the complaint for lack of standing. The plaintiffs appealed to the Wyoming Supreme Court.The Supreme Court of Wyoming affirmed the district court’s dismissal. The court held that the plaintiffs failed to establish prudential standing under Wyoming’s Brimmer test, which requires a tangible personal stake in the outcome, not just a generalized grievance. The court also declined to recognize taxpayer standing, since the plaintiffs’ claims of increased tax burdens were speculative and unsupported by specific factual allegations. Even though the plaintiffs argued the case was of great public importance, the court held that public interest alone is insufficient to relax standing requirements without a concrete, particularized harm. As a result, the Supreme Court affirmed the dismissal of the action for lack of standing. View "Williams v. Board of County Commissioners of Johnson County" on Justia Law

The case concerns challenges to groundwater replenishment charges imposed by a water district in a desert region where groundwater is the main source of potable water. The water district operates three areas of benefit (AOBs) and levies replenishment charges on customers who pump significant groundwater. Domestic customers do not pay these charges directly, but their payments for drinking water are allocated to the replenishment funds through the district’s enterprise fund system. Plaintiffs, including a taxpayer association, alleged that the replenishment charges were unconstitutionally structured, resulting in higher rates for certain AOBs and unfair subsidies for others, benefitting large agricultural businesses.The litigation began with a combined petition and class action in the Superior Court of Riverside County, which was dismissed because the court found the validation statutes applied and the statute of limitations had expired. Subsequent reverse validation actions for later fiscal years were timely filed and consolidated. The Superior Court, in rulings by two judges, found the replenishment charges to be unconstitutional taxes because they did not satisfy the requirements of California Constitution Article XIII C, Section 1, subdivision (e)(2). Specifically, the court found that the district failed to show the allocation of replenishment costs bore a fair or reasonable relationship to the burdens or benefits received by each AOB, and thus the charges were not exempt from being classified as taxes. The court awarded substantial refunds to affected ratepayers and enjoined the district from imposing similar unconstitutional charges in the future.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed both the district’s appeal of the remedies and liability findings and the taxpayer association’s cross-appeal on procedural grounds. The appellate court affirmed in full, holding that the replenishment charges were unconstitutional, the remedies were proper, and that the validation statutes applied to these charges, thus barring untimely claims for earlier years. The appellate court also found no error in the trial court’s grant of refund and injunctive relief. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

The plaintiffs, a microbrewery and its owner, operated a seasonal business in a tourist town and became known for engaging in political advocacy. The business applied for various permits to operate both an indoor retail outlet and, later, an outdoor beer garden. Despite being granted permits that included specific conditions—such as restrictions on outdoor operations—the plaintiffs repeatedly violated these conditions, operated without proper permits, and explicitly stated their intention to continue doing so regardless of regulatory decisions. Throughout this period, the owner was vocal in criticizing local officials on social media.After several rounds of permit applications, denials, suspensions, and revocations, the plaintiffs’ most recent permit application for an outdoor beer garden was denied by the county committee, which cited the plaintiffs’ ongoing and willful violations of permit conditions and their declared intent to continue such violations. The plaintiffs appealed administrative actions to the Oneida County Board of Adjustment, which upheld the revocations. Subsequently, the plaintiffs filed a lawsuit in the United States District Court for the Western District of Wisconsin, asserting that the permit denials and revocations constituted retaliation for protected political speech, in violation of the First Amendment. They sought a preliminary injunction to reinstate their permit and prevent further alleged retaliation.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the preliminary injunction and affirmed it. The Seventh Circuit held that, while the plaintiffs engaged in protected speech and suffered adverse permit actions, they failed to demonstrate a likelihood of success on the merits of their First Amendment retaliation claim. The court concluded that the permit denials and revocations were based on the plaintiffs’ repeated and admitted violations of permit conditions, not on retaliatory motives, and that the plaintiffs offered no evidence of disparate treatment or pretext. View "Minocqua Brewing Company LLC v Hess" on Justia Law

An agricultural company opposed a unionization effort initiated by the United Farm Workers of America, who sought certification as the exclusive bargaining representative for the company's employees under a new statutory procedure. The union filed a Majority Support Petition with the Agricultural Labor Relations Board, presenting evidence that a majority of employees supported union representation. The company responded by submitting objections and employee declarations alleging misconduct by the union during the signature collection process. The Board's regional director investigated and determined that the union had met the statutory criteria for certification, leading the Board to certify the union as the employees' representative.Following the certification, the company filed additional objections with the Agricultural Labor Relations Board, including constitutional challenges to the underlying statute. The Board dismissed most objections and set others for a hearing, but stated it could not rule on constitutional questions. While administrative proceedings were ongoing, the company filed a petition in the Superior Court of Kern County seeking to enjoin the Board from proceeding and to declare the statute unconstitutional. The Board and the union argued that the court lacked jurisdiction due to statutory limits on judicial review, but the superior court nonetheless issued a preliminary injunction halting the Board's proceedings. Appeals and writ petitions followed, consolidating the matter before the reviewing court.The Court of Appeal of the State of California, Fifth Appellate District, held that the superior court lacked jurisdiction to consider the challenge at this stage. The court reaffirmed that under California law, employers may not directly challenge union certification decisions in court except in extraordinary circumstances, which were not present here. The proper procedure is for employers to wait until an unfair labor practice proceeding or mandatory mediation is completed and a final order is issued before seeking judicial review. The court reversed the preliminary injunction and ordered dismissal of the company’s petition for lack of jurisdiction. View "Wonderful Nurseries v. Agricultural Labor Relations Board" on Justia Law

John Kenney, a resident of Florida, sought to obtain a retail cannabis license in Rhode Island as a social equity applicant. He argued that, as a recipient of a social equity cannabis license in the District of Columbia and someone with nonviolent marijuana convictions in Maryland and Nevada, he would otherwise qualify under Rhode Island’s Cannabis Act. Kenney challenged two provisions of the Act: the requirement that all license applicants must be Rhode Island residents or entities controlled by Rhode Island residents, and the definition of “social equity applicant,” which, according to Kenney, only recognizes nonviolent marijuana offenses eligible for expungement under Rhode Island law.After Kenney filed an amended complaint in the United States District Court for the District of Rhode Island, the defendants moved to dismiss for failure to state a claim and lack of subject matter jurisdiction. On February 6, 2025, the district court dismissed the case on ripeness grounds, reasoning that the Cannabis Control Commission had not yet promulgated final rules for retail cannabis licenses, and thus the court could not adjudicate the claims. The case was dismissed without prejudice, and Kenney appealed.The United States Court of Appeals for the First Circuit reviewed the appeal. Following the Commission’s issuance of final rules for retail cannabis licenses, effective May 1, 2025, the appellate court determined that the district court erred in dismissing the case for lack of ripeness. The First Circuit held that Kenney’s claims were not moot and that he had standing to pursue them. The court reversed the district court’s dismissal order and remanded the case for prompt consideration of the merits of Kenney’s constitutional challenges, instructing the district court to rule at least forty-five days before the Commission issues retail licenses. View "Kenney v. Rhode Island Cannabis Control Commission" on Justia Law