Justia Government & Administrative Law Opinion Summaries

In this action for declaratory judgment the Supreme Court reversed the judgment of the court of appeals reversing the decision of the district court finding that the City of Imperial, Nebraska was financially responsible for $436 in medical costs incurred by a person who was arrested, holding that declaratory judgment was not available.An arrestee filed this declaratory judgment seeking a determination that the City was solely responsible for the medical expenses the arrestee incurred when he was required to submit to a physical examination before being placed in jail. The district court agreed that the City was responsible for the arrestee’s medical costs. The court of appeals reversed, determining that Chase County, Nebraska was the responsible party. The Supreme Court reversed, holding that declaratory judgment was not available due to the lack of a justiciable controversy between the parties. The Court remanded the cause with directions to vacate the district court’s judgment. View "Chase County v. City of Imperial" on Justia Law

The Supreme Court affirmed the circuit court’s dismissal of Appellant’s petition for judicial review under the Arkansas Administrative Procedure, declaratory relief, and petition for writ of mandamus, holding that the circuit court did not err in denying relief.In his petition, Appellant challenged the decision of the Arkansas Board of Parole denying him parole for an additional year. The circuit court held that Appellant failed to state a claim establishing a constitutional violation that would allow for judicial review or injunctive relief. The court denied the petition for writ of mandamus, concluding that the Board’s decision was discretionary. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion in finding that Appellant’s speculative claim could not survive a motion to dismiss; and (2) did not err in denying the writ of mandamus. View "Null v. Arkansas Parole Board" on Justia Law

In 1998, petitioner Christal Fields pled guilty to attempted second degree robbery for trying to snatch a woman's purse. As a result, Fields was permanently disqualified from working at any licensed childcare facility in Washington pursuant to Department of Early Learning (DEL) regulations. At issue in this case was the extent to which a criminal record could preclude a person from supporting herself through lawful employment in her chosen field. The Washington Supreme Court held DEL's regulations prohibiting any individualized consideration of Fields' qualifications at the administrative level violated her federal right to due process as applied. The Court reversed the Court of Appeals and remanded for further administrative proceedings. View "Fields v. Dep't of Early Learning" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) to uphold the suspension of Appellant’s driver’s license, holding that collateral estoppel did not bar the OAH from considering Appellants’ blood alcohol content (BAC) test results in the license suspension proceeding.In the companion criminal case, the municipal court dismissed Appellant’s criminal charges without prejudice without referring to the prosecution’s argument that a gap in the chain of custody of Appellant’s blood samples rendered the BAC test results inadmissible. On appeal from the OAH proceedings, Appellant argued that the OAH was collaterally estopped from considering the BAC test results in the license suspension proceeding. The Supreme Court disagreed, holding that all four collateral estoppel requirements were not met under the circumstances. View "Casiano v. State ex rel. Wyoming Department of Transportation" on Justia Law

In an act of road rage, Bedford fired two shots at a truck driver while they both headed westbound on Interstate 40 in Tennessee. The truck driver, P.D., was employed by P&R, a private trucking company that had a contract with the United States Postal Service (USPS) to transport mail, and was carrying U.S. mail. Bedford was charged with forcibly assaulting, resisting, opposing, impeding, intimidating, or interfering with a person assisting officers and employees of the United States, while that person was engaged in the performance of official duties, and in doing so, using a dangerous weapon, 18 U.S.C. 111(a)(1), (b). Bedford moved to dismiss the indictment for lack of jurisdiction, contending that P.D. was not an officer or employee of the United States within the meaning of 18 U.S.C. 1114. The district court denied the motion, finding that the driver was a person assisting a federal officer or employee and fell within the statute’s reach. Bedford now appeals that denial. The Sixth Circuit affirmed. When a private mail carrier, pursuant to formal contract, carries U.S. mail on behalf of the USPS, he assists an officer or employee of the United States in the performance of official duties. View "United States v. Bedford" on Justia Law

The Sexually Violent Predators Act (SVPA) provides the court with discretionary authority to involuntarily medicate an incompetent person placed with the State Hospital pre-commitment. The Court of Appeal affirmed the trial court's order finding that defendant lacked the capacity to refuse treatment and compelling him to undergo the involuntary administration of antipsychotic medication by the State Department of State Hospitals. In this case, although defendant has not been committed to the State Hospital, the trial court had the discretionary authority under Welfare and Institutions Code section 6602.5 to order his involuntary medication upon a proper finding he was incompetent to refuse medical treatment. Defendant was represented by counsel, provided with a full evidentiary hearing on request, and the trial court expressly found that defendant lacked the capacity to refuse treatment. View "State Department of State Hospitals v. J.W." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s complaint for a writ of mandamus against the director of the Ohio Department of Rehabilitation and Correction (DRC), holding that there was no error in the court of appeals’ judgment.Appellant, an inmate, filed a complaint requesting a writ of mandamus to order DRC to remove a federal detainer that Appellant alleged was erroneously placed on his prison record. After DRC removed the detainer, the director filed a motion to dismiss the complaint, Thereafter, Appellant filed a motion for declaratory judgment seeking to prevent placement of future detainers. The court of appeals dismissed the complaint as moot. The Supreme Court affirmed, holding that the court of appeals (1) properly dismissed Appellant’s complaint because the detainer was no longer on Appellant’s prison record; (2) correctly denied Appellant’s motion for declaratory judgment; and (3) did not err in denying Appellant’s motion for summary judgment. View "State ex rel. Evans v. Mohr" on Justia Law

The North Dakota Department of Transportation appealed a district court judgment reversing the Department's decision to suspend Dustin LeClair's driving privileges. The Department argued the district court erred in reversing its decision to suspend LeClair's license because the officer's recitation of the implied consent advisory, which excluded the word "punishable," substantially complied with N.D.C.C. 39-20-01(3)(a). After review, the North Dakota Supreme Court reversed the district court's judgment and reinstated the Department's decision to suspend LeClair's driving privileges. View "LeClair v. Sorel" on Justia Law

Wilbur Paul Hunts Along appealed a judgment affirming the Department of Transportation's revocation of his driving privileges for two years. Hunts Along argued the Department failed to show that Hunts Along refused to submit to testing "under section . . . 39-20-14," and therefore revocation under N.D.C.C. 39-20-04(1) was improper. After review, the North Dakota Supreme Court concluded the Department did not err in finding that Hunts Along refused to submit to an onsite screening test. View "Hunts Along v. N.D. Dep't of Transportation" on Justia Law

The City of Grand Forks appealed a district court order suppressing the results of Thomas Barendt's chemical breath test after the City charged Barendt with actual physical control of a vehicle while under the influence of alcohol. The North Dakota Supreme Court affirmed, concluding North Dakota's implied consent advisory had to be read after placing an individual under arrest and before the administration of a chemical test. View "City of Grand Forks v. Barendt" on Justia Law