Justia Government & Administrative Law Opinion Summaries

The dispute centers on approximately 930 acres of agricultural land owned by two trusts near Pocatello, Idaho. The trusts entered into a purchase and sales agreement with a developer, Millennial Development Partners, to sell a strip of land for a new road, Northgate Parkway, which was to provide access to their property. The trusts allege that Millennial and its partners, along with the City of Pocatello, failed to construct promised access points and infrastructure, and that the developers and city officials conspired to devalue the trusts’ property, interfere with potential sales, and ultimately force a sale below market value. The trusts claim these actions diminished their property’s value and constituted breach of contract, fraud, interference with economic advantage, regulatory taking, and civil conspiracy.After the trusts filed suit in the District Court of the Sixth Judicial District, Bannock County, the defendants moved for summary judgment. The trusts sought to delay the proceedings to complete additional discovery, arguing that the defendants had not adequately responded to discovery requests. The district court denied both of the trusts’ motions to continue, struck their late response to the summary judgment motions as untimely, and granted summary judgment in favor of the defendants, dismissing the case with prejudice and awarding attorney fees to the defendants. The trusts appealed these decisions.The Supreme Court of the State of Idaho affirmed the district court’s denial of the trusts’ motions to continue, finding no abuse of discretion. However, it reversed the grant of summary judgment, holding that the district court erred by failing to analyze whether the defendants had met their burden under the summary judgment standard and appeared to have granted summary judgment as a sanction for the trusts’ untimely response. The Supreme Court vacated the judgment and remanded the case for further proceedings, and declined to award attorney fees on appeal. View "Rupp v. City of Pocatello" on Justia Law

A state port authority and a group of related companies entered into a series of letters of intent (LOIs) regarding the possible expansion and operation of a port facility. The final LOI, signed in December 2019, included provisions for confidentiality, exclusivity, and certain legally binding terms, but also stated that it was not a binding agreement to consummate the potential transaction. The port authority’s board approved the LOI and several subsequent extensions, but the board minutes did not include the terms or conditions of the LOI. After negotiations failed, the port authority terminated the LOI. The companies claimed significant losses and alleged the port authority had breached the LOI and misused confidential information.The Harrison County Circuit Court found that the LOI was unenforceable under Mississippi’s “minutes rule,” which requires that public board contracts be sufficiently detailed in the board’s official minutes. The court dismissed all claims based on the LOI, including breach of contract and quantum meruit, but allowed claims for unjust enrichment and misappropriation of trade secrets to proceed. Both parties sought interlocutory appeal, and the appeals were consolidated.The Supreme Court of Mississippi affirmed the lower court’s ruling that the LOI was unenforceable because the board minutes did not contain enough terms to determine the parties’ obligations, and held that the minutes rule was not superseded by the Open Meetings Act. The court also held that unjust enrichment, as an implied contract claim, was barred by the minutes rule and reversed the trial court’s denial of summary judgment on that claim. However, the court affirmed that the companies’ notice of claim regarding misappropriation of trade secrets was sufficient under the Mississippi Tort Claims Act. The case was remanded for further proceedings on the remaining claim. View "The Mississippi State Port Authority at Gulfport v. Yilport Holding A.S." on Justia Law

After the collapse of a federally chartered credit union in Ohio in 2010, the National Credit Union Administration Board (the Board) was appointed as liquidating agent. The Board sued Eddy Zai, his wife Tina Zai, and related entities to recover tens of millions of dollars allegedly owed to the credit union. The parties settled, with the Zais agreeing to transfer a promissory note to the Board, which would collect $22 million and then transfer the note to Tina Zai. Years later, Tina Zai alleged that the Board breached the settlement by failing to timely transfer the note after collecting the agreed sum. She, along with Stretford, Ltd., filed suit against the Board for breach of contract and unjust enrichment.The United States District Court for the Northern District of Ohio dismissed the case for lack of subject-matter jurisdiction, without reaching the merits of Zai’s claims. The district court reasoned that the Federal Credit Union Act’s jurisdiction-stripping provision barred the court from hearing the case, as Zai had not exhausted administrative remedies with the Board.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the district court had jurisdiction. The Sixth Circuit held that the Federal Credit Union Act’s jurisdiction-stripping and administrative-exhaustion provisions apply only to claims that arise before the Board’s claims-processing deadline. Because Zai’s claim for breach of the settlement agreement arose years after the deadline, she was not required to exhaust administrative remedies, and the jurisdictional bar did not apply. The Sixth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Zai v. National Credit Union Administration Board" on Justia Law

The dispute arose when a property owner, after selling his San Diego County home and purchasing property in Trinity County, sought to transfer the base year value of his former property to his new one. In 2009, he sued the Trinity County Board of Supervisors to compel such a transfer under California law. The parties settled in 2012, agreeing that if the County later adopted an ordinance or if a change in law required it, the owner would be entitled to retroactively transfer the base year value. In 2020, after the passage of Proposition 19, which expanded the ability to transfer base year values between counties, the owner requested the transfer from the county assessor, who denied the request.The Superior Court of Trinity County held a bench trial and found in favor of the property owner on his breach of contract claims, ordering the County to specifically perform the settlement agreement and awarding damages. The court rejected the County’s arguments that the agreement was limited to intra-county transfers and that the Board lacked authority to bind the assessor. The court also found that the new law triggered the County’s obligations under the agreement.On appeal, the California Court of Appeal, Third Appellate District, concluded that the Board of Supervisors did not have the authority to direct the county assessor in setting or transferring base year values, as this is a duty assigned by law to the assessor, an elected official independent of the Board’s control. The court held that the 2012 settlement agreement was void and unenforceable because it exceeded the Board’s legal authority. As a result, the judgment on the breach of contract claims was reversed, while the remainder of the judgment was affirmed. The County was awarded its costs on appeal. View "Sceper v. County of Trinity" on Justia Law

During the COVID-19 pandemic, Congress established the Paycheck Protection Program (PPP) to help eligible small businesses maintain payroll through government-mandated shutdowns. The program, administered by the Small Business Administration (SBA), provided for government-guaranteed loans to qualifying businesses, with the possibility of loan forgiveness if certain conditions were met. Bruckner Truck Sales received a $10 million PPP loan, but the SBA later determined that Bruckner was not eligible for the loan. Despite conceding its ineligibility, Bruckner refused to return the funds and instead claimed entitlement to loan forgiveness under the CARES Act.The United States District Court for the Northern District of Texas reviewed the case after Bruckner challenged the SBA’s denial of forgiveness. The district court granted summary judgment in favor of the government, holding that the CARES Act does not entitle ineligible borrowers to loan forgiveness. The court also denied Bruckner’s motion to alter or amend the judgment, finding that the SBA’s interpretation of the statute was correct and that the agency’s actions were not arbitrary or capricious.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s decision. The Fifth Circuit held that the CARES Act limits loan forgiveness to borrowers who were eligible for the underlying PPP loan. The court rejected Bruckner’s arguments that the SBA’s rule was retroactive, that the agency violated the Chenery doctrine, and that the district court improperly deferred to the agency’s interpretation. The court concluded that neither the text nor the structure of the CARES Act supports forgiveness for ineligible borrowers, and affirmed the denial of loan forgiveness and the requirement to return the funds. View "Bruckner Truck Sales v. Guzman" on Justia Law

CPI Security Systems, Inc. filed a lawsuit against Vivint Smart Home, Inc., alleging that Vivint engaged in deceptive practices to lure away CPI’s customers. Vivint sales representatives falsely claimed that Vivint had acquired CPI, that CPI was going out of business, or that Vivint needed to upgrade CPI’s equipment. These tactics led many CPI customers to switch to Vivint, causing significant losses for CPI. A jury found Vivint liable for violating the Lanham Act, the North Carolina Unfair and Deceptive Trade Practices Act (UDTPA), and for committing the common-law torts of unfair competition and tortious interference with contracts. The jury awarded CPI $49.7 million in compensatory damages and $140 million in punitive damages.The United States District Court for the Western District of North Carolina upheld the jury’s verdict. Vivint appealed, raising several issues, including the requirement of CPI’s reliance on false statements for the UDTPA claim, the sufficiency of evidence supporting the damages award, the application of North Carolina’s cap on punitive damages, and the admission of prejudicial evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case and found no reversible error. The court held that CPI was not required to prove its own reliance on Vivint’s false statements to establish a UDTPA claim, as the claim was based on unfair competition rather than fraud. The court also found that the evidence presented by CPI was sufficient to support the jury’s damages award. Additionally, the court ruled that the district court correctly applied North Carolina’s cap on punitive damages by considering the total compensatory damages awarded. The court further held that the district court did not abuse its discretion in denying Vivint’s motion to bifurcate the trial or in its evidentiary rulings. The reassignment of the trial judge post-trial did not warrant a new trial. Consequently, the Fourth Circuit affirmed the district court’s judgment. View "CPI Security Systems, Inc. v. Vivint Smart Home, Inc." on Justia Law

Crowley Government Services, Inc. ("Crowley") entered into a contract with the Department of Defense United States Transportation Command ("USTRANSCOM") in 2016 to provide transportation coordination services, which involved hiring motor carriers to transport freight. The General Services Administration ("GSA"), not a party to the contract, began auditing Crowley's bills under a provision of the Transportation Act of 1940, claiming Crowley overbilled USTRANSCOM by millions of dollars. GSA sought to recover these overcharges by garnishing future payments to Crowley.The United States District Court for the District of Columbia dismissed Crowley's Administrative Procedure Act ("APA") claims, holding that the claims were essentially contractual and fell within the exclusive jurisdiction of the Court of Federal Claims. The D.C. Circuit reversed, finding that Crowley's suit was not a contract claim and remanded the case. On remand, the District Court held that GSA could audit both carriers and non-carriers but agreed with Crowley that the USTRANSCOM Contracting Officer's interpretations governed any GSA audits. The court enjoined GSA from issuing Notices of Overcharge ("NOCs") contrary to the Contracting Officer's determinations.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that 31 U.S.C. § 3726(b) allows GSA to audit only bills presented by carriers and freight forwarders. The court found that Crowley is not a carrier because it does not physically transport freight nor is it contractually bound to help perform the movement of goods. Consequently, the court reversed the District Court's decision on the scope of § 3726(b) and remanded for further proceedings, permanently enjoining GSA from conducting postpayment audits of Crowley's bills. View "Crowley Government Services, Inc. v. General Services Administration" on Justia Law

Anthony Rojas, a student at the University of Florida, filed a class action lawsuit against the University of Florida Board of Trustees. Rojas claimed that the University breached its contract by suspending on-campus services and closing facilities during the COVID-19 pandemic, despite students being required to pay mandatory fees for these services. He also alleged that the University failed to refund these fees. The complaint included a spring 2020 tuition statement, a general statement of tuition and fee estimates for the 2019-2020 academic year, and the University’s financial liability agreement.The trial court dismissed the unjust enrichment claim but denied the University’s motion to dismiss the breach of contract claim, ruling that the complaint adequately pleaded the existence of an express contract. The University appealed, and the First District Court of Appeal reversed the trial court’s decision, holding that the claims were barred by sovereign immunity. The First District concluded that the contract alleged by Rojas did not constitute an express written contract sufficient to overcome sovereign immunity.The Supreme Court of Florida reviewed the case and quashed the First District’s decision. The Court held that the waiver-by-contract doctrine does not preclude claims based on the breach of implied covenants or conditions that do not conflict with express contract provisions. The Court found that the First District erred in requiring extraordinary specificity in government contracts and in failing to recognize permissible implied covenants. The case was remanded for further proceedings consistent with this opinion. View "Rojas v. University of Florida Board of Trustees" on Justia Law

A resident taxpayer of Omaha challenged the City of Omaha's contract for residential solid waste collection, alleging it was an illegal expenditure of public funds and violated the Integrated Solid Waste Management Act (ISWMA). The contract, awarded to FCC Environmental Services Nebraska, LLC (FCC-Nebraska), included a yard waste sticker program where residents could purchase stickers for additional yard waste disposal.The district court for Douglas County granted summary judgment in favor of the City and FCC-Nebraska, dismissing the taxpayer's claims. The court found that the City acted within its discretion in seeking a postopening bid clarification from FCC-Spain (the original bidder) to standardize the unit price for yard waste stickers, which did not materially alter the bid or give FCC an unfair advantage. The court also determined that the yard waste sticker fee charged by FCC did not require voter approval under § 13-2020(4) of the ISWMA, as the fee was charged by and paid to the contractor, not the City.The Nebraska Supreme Court affirmed the district court's decision. It held that the City did not act in bad faith or with favoritism in seeking the bid clarification and that the clarification did not result in a material variance from FCC's original bid. The court also agreed that the voter approval requirement in § 13-2020(4) did not apply to the yard waste sticker fee, as it was governed by § 13-2020(5), which allows contractors to charge service rates without voter approval. The court concluded that the district court did not abuse its discretion in denying the taxpayer's motion to amend the complaint to add a new theory of invalidity based on the identity of the contracting party. View "Johnson v. City of Omaha" on Justia Law

Michigan Electric Transmission Company (METC) owns a high-voltage transmission line with Michigan Public Power Agency (MPPA) and Wolverine Power Supply Cooperative. The case concerns the ownership of new transmission facilities, or "network upgrades," connecting a new solar generation park to the transmission line. METC claims exclusive ownership based on existing agreements, while MPPA and Wolverine disagree.The Federal Energy Regulatory Commission (FERC) reviewed the case and found that no agreement conclusively determined ownership rights. FERC declined to decide the ownership question, leading METC to petition for review.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court agreed with FERC's interpretation that the relevant agreements did not grant METC exclusive ownership of the network upgrades. The court found that the Styx-Murphy line qualifies as a "system" under the Transmission Owners Agreement (TOA), and since METC is not the sole owner, it cannot claim exclusive ownership. The court also found that the Styx-Murphy Agreements did not preclude MPPA and Wolverine from owning network upgrades.The court denied METC's petitions for review, upholding FERC's decision. View "Michigan Electric Transmission Company, LLC v. FERC" on Justia Law