Justia Government & Administrative Law Opinion Summaries

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

The case involves James Harper, who challenged an IRS "John Doe" summons issued to Coinbase, a cryptocurrency exchange, seeking records of numerous customers, including Harper. Harper argued that the IRS's actions violated his Fourth and Fifth Amendment rights and did not meet statutory requirements under the Administrative Procedure Act (APA). The IRS had issued the summons to investigate potential tax noncompliance among Coinbase users.The United States District Court for the District of New Hampshire dismissed Harper's complaint. The court found that Harper lacked a reasonable expectation of privacy in his Coinbase account information and that the records were Coinbase's property, not Harper's. The court also concluded that the IRS summons was reasonable and that Harper had received constitutionally adequate process. Additionally, the court dismissed Harper's statutory challenge, ruling it was an improper collateral attack on prior district court proceedings that had enforced the summons and found it met statutory standards.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Harper lacked a protectable interest under the Fourth or Fifth Amendment. It held that Harper had no reasonable expectation of privacy in the information he voluntarily provided to Coinbase and that the records were Coinbase's property. The court also found that Harper's due process claim failed because he had no protected liberty interest in the confidentiality of his financial information. Finally, the court ruled that the IRS summons was not "final agency action" under the APA, thus not subject to judicial review.The First Circuit affirmed the district court's dismissal of Harper's complaint, concluding that Harper's constitutional and statutory claims were without merit. View "Harper v. Werfel" on Justia Law

The case involves Robert Holman, who challenged a debt-relief program under the American Rescue Plan Act that provided benefits to "socially disadvantaged" farmers and ranchers based on racial categories. Holman, a farmer, argued that he was excluded from the program solely due to his race and sought a preliminary injunction to halt the program. The district court granted the preliminary injunction, finding that the program did not meet the strict scrutiny standard required for racial classifications under the Fifth Amendment. However, before a final judgment was reached, Congress repealed the program, leading Holman to seek attorney's fees under the Equal Access to Justice Act (EAJA).The United States District Court for the Western District of Tennessee denied Holman's request for fees, ruling that he was not a "prevailing party" under the EAJA because the preliminary injunction did not provide him with lasting relief. The court also noted that the injunction was temporary and revocable, and thus did not materially alter the legal relationship between the parties.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court did not definitively rule on whether Holman was a "prevailing party" but found that the Government's position during the litigation was "substantially justified" under the EAJA. The court noted that the Government had presented substantial evidence to defend the program's constitutionality, including historical discrimination against minority farmers by the USDA. The court concluded that a reasonable person could find the Government's position justified, thereby precluding Holman's entitlement to attorney's fees and expenses. View "Holman v. Vilsack" on Justia Law

The case involves the Horseracing Integrity and Safety Act, which establishes a framework to regulate horseracing through the Horseracing Integrity and Safety Authority, a private nonprofit corporation. The Authority is responsible for creating and enforcing rules related to horseracing, subject to oversight by the Federal Trade Commission (FTC). Bill Walmsley, Jon Moss, and the Iowa Horsemen’s Benevolent and Protective Association sought a preliminary injunction to prevent the enforcement of rules under the Act, arguing that the Act was unconstitutional.The United States District Court for the Eastern District of Arkansas denied the motion for a preliminary injunction, finding that the plaintiffs were unlikely to succeed on the merits of their constitutional challenges. The plaintiffs then appealed to the United States Court of Appeals for the Eighth Circuit.The Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Act's rulemaking structure does not violate the private nondelegation doctrine because the FTC has ultimate discretion over the rules governing the horseracing industry. The court also found that the Act does not unconstitutionally delegate executive power to the Authority, as the FTC has pervasive oversight and control over the Authority's enforcement activities. Additionally, the court concluded that the Act provides an intelligible principle for the FTC to follow, thus not violating the public nondelegation doctrine. Finally, the court determined that the Authority's board members are not officers of the United States and therefore not subject to the Appointments Clause.The Eighth Circuit concluded that Walmsley did not demonstrate a fair chance of success on the merits, and thus, the district court did not abuse its discretion in denying the preliminary injunction. The order of the district court was affirmed. View "Walmsley v. FTC" on Justia Law

A proposed constitutional amendment in Ohio seeks to repeal Articles XI and XIX of the Ohio Constitution and add Article XX, changing the standards and procedures for drawing electoral districts. The amendment would create a 15-member redistricting commission responsible for adopting redistricting plans. Citizens Not Politicians, a coalition aiming to end gerrymandering, and other relators challenged the ballot language and title adopted by the Ohio Ballot Board and Secretary of State Frank LaRose, arguing they were misleading.The Ohio Ballot Board approved the ballot language by a three-to-two vote. Relators filed for a writ of mandamus to compel the board to adopt new language and title. The Supreme Court of Ohio reviewed the case, focusing on whether the ballot language and title would mislead, deceive, or defraud voters. The court found that sections five and eight of the ballot language were misleading. Section five inaccurately limited judicial review to a "proportionality standard," and section eight failed to mention the public's right to participate in the redistricting process through public meetings and hearings.The Supreme Court of Ohio granted a limited writ of mandamus, ordering the Ohio Ballot Board and Secretary of State to reconvene and adopt revised ballot language addressing these defects. The court denied the writ in all other respects, finding the remaining sections of the ballot language and the ballot title to be factually accurate and not misleading. The motion for leave to withdraw the answer was granted, and the motion to strike was denied as moot. View "State ex rel. Citizens Not Politicians v. Ohio Ballot Bd." on Justia Law

Three Libertarian Party candidates for the U.S. House of Representatives were disqualified from the 2024 general election ballot by the State Objection Panel for failing to comply with Iowa's statutory nomination requirements. The candidates, Nicholas Gluba, Charles Aldrich, and Marco Battaglia, were nominated at a party convention after no Libertarian candidates filed for the primary election. However, the party did not follow the required process for selecting delegates to the convention, which included holding precinct caucuses and county conventions on separate days and notifying county auditors of the delegates.The Iowa District Court for Polk County upheld the Panel's decision, finding that the Libertarian Party did not comply with Iowa Code section 43.94, which mandates that county convention delegates' terms begin the day after their election at precinct caucuses. The court ruled that strict compliance with this law was necessary, and the party's failure to follow the process invalidated the nominations. The court also rejected arguments that the objectors lacked standing and that the Panel's decision violated the candidates' First Amendment rights.The Iowa Supreme Court affirmed the district court's ruling. The court held that the statutory requirements for nominating candidates by convention must be strictly followed and that the Libertarian Party's failure to comply with these requirements justified the disqualification of the candidates. The court also found that the objectors had standing to challenge the nominations and that the Panel's decision did not violate the candidates' First Amendment rights. The court emphasized that the election laws are designed to ensure a fair and orderly process for candidate nominations. View "Gluba v. State Objection Panel" on Justia Law

A psychiatrist employed at a public university's medical school participated in a panel discussion on childhood gender dysphoria, expressing views that were unpopular with his colleagues and supervisors. Following his remarks, he was demoted and his contract was not renewed after over fifteen years of employment. He sued several university officials, alleging First Amendment retaliation.The United States District Court for the Western District of Kentucky denied the defendants' motions for summary judgment, which argued for Eleventh Amendment immunity and qualified immunity. The court found material fact disputes regarding whether the defendants retaliated against the plaintiff for his protected speech.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiff's speech was protected under the First Amendment as it addressed a matter of public concern and was not made pursuant to his official duties. The court also found that the plaintiff's interest in speaking on the topic outweighed the university's interest in maintaining workplace efficiency. The court determined that the adverse actions taken against the plaintiff, including his demotion and contract nonrenewal, were motivated by his protected speech.The Sixth Circuit affirmed the district court's denial of summary judgment, concluding that the defendants were not entitled to Eleventh Amendment immunity or qualified immunity. The court held that the plaintiff's rights were clearly established and that a reasonable university official would have understood that retaliating against him for his speech was unlawful. The court also denied the plaintiff's motion to dismiss the appeal for lack of jurisdiction as moot. View "Josephson v. Ganzel" on Justia Law

A non-profit organization, Citizens for Constitutional Integrity, sued the Census Bureau, the Department of Commerce, and related officials, alleging that the Bureau failed to proportionately reduce the basis of representation for states in the 2020 Census as required by the Fourteenth Amendment's Reduction Clause. Citizens claimed this failure diluted the voting power of its members in New York, Pennsylvania, and Virginia. The organization sought relief under the Administrative Procedure Act (APA) and a writ of mandamus.The United States District Court for the District of Columbia dismissed the case for lack of standing. The court found that Citizens could not demonstrate that its alleged vote dilution injury was traceable to the Bureau's actions. Specifically, the court noted that Citizens failed to show how the Bureau's failure to apply the Reduction Clause directly caused the loss of congressional representation for the states in question. The court also found the data scientist's declaration provided by Citizens unpersuasive, as it did not adequately account for the number of disenfranchised voters in the relevant states.The United States Court of Appeals for the District of Columbia Circuit affirmed the District Court's dismissal. The appellate court held that Citizens did not establish traceability under Article III standards. The court found that Citizens failed to present a feasible alternative methodology for apportionment that would have resulted in a different allocation of seats for New York, Pennsylvania, and Virginia. The court also rejected Citizens's argument that it was entitled to a relaxed standing requirement for procedural-rights cases, concluding that the challenge was substantive rather than procedural. Consequently, the court affirmed the District Court's ruling that Citizens lacked standing to pursue its claims. View "Citizens for Constitutional Integrity v. Census Bureau" on Justia Law