Justia Government & Administrative Law Opinion Summaries

Kimani E. Ware, currently incarcerated, filed a complaint for a writ of mandamus in the Fifth District Court of Appeals, seeking to compel the Stark County Prosecuting Attorney to produce records in response to a public-records request. Ware claimed he sent the request by certified mail in April 2022, asking for the prosecutor’s office’s employee roster and budget reports from January 2019 to January 2022. The prosecutor denied receiving this request, asserting that the certified mail contained a court filing from another case, not a public-records request.The Fifth District Court of Appeals granted the prosecutor’s motion for summary judgment, denied Ware’s motion for summary judgment, and ruled the writ request moot since the prosecutor provided the requested records after being served with the mandamus complaint. The court also denied Ware’s request for statutory damages and court costs, concluding that Ware did not prove by clear and convincing evidence that he delivered the public-records request in April 2022.The Supreme Court of Ohio reviewed the case and affirmed the lower court’s judgment. The court held that the prosecutor’s office did not act in bad faith by providing the records after the mandamus complaint was filed, as there was no clear evidence that the public-records request was delivered in April 2022. The court also upheld the denial of statutory damages and court costs, agreeing with the lower court’s findings and procedures. The court concluded that the prosecutor’s response time of 11 days after receiving the mandamus complaint was reasonable. View "State ex rel. Ware v. Stone" on Justia Law

Cleveland Stegall was employed at an FCA vehicle assembly plant through a staffing agency, Brightwing. In late 2015, FCA announced plans to eliminate Stegall’s shift by summer 2016. In April 2016, Stegall raised concerns about asbestos in the workplace to his FCA supervisors, who promised air quality tests but did not provide results. Stegall continued to request the results and threatened to file complaints with OSHA and Michigan OSHA. He was terminated on June 17, 2016, and subsequently filed a discrimination complaint with Michigan OSHA, alleging retaliation for his asbestos concerns.The Oakland Circuit Court granted summary disposition for both defendants, ruling that Stegall’s public-policy claim was preempted by the Whistleblowers’ Protection Act (WPA) and that internal complaints could not support a public-policy claim. The Michigan Court of Appeals affirmed, agreeing that the public-policy claim was preempted and could not be based on internal reporting. The Michigan Supreme Court reversed in part, holding that internal reporting could support a public-policy claim and remanded for further consideration of whether the claim was preempted by other laws.On remand, the Court of Appeals concluded that Stegall’s public-policy claim was preempted by OSHA and MiOSHA, as these statutes provided exclusive remedies for retaliation. The Michigan Supreme Court reviewed the case and held that the remedies under OSHA and MiOSHA were inadequate and thus not exclusive. Therefore, Stegall’s public-policy claim was not preempted. The case was remanded to the trial court to determine if there was a genuine issue of material fact regarding Stegall’s claim of wrongful termination in violation of public policy. View "Stegall V Resource Technology Corporation" on Justia Law

The plaintiffs, five Muslim U.S. citizens, allege they have been placed on the Terrorist Screening Dataset, commonly known as the "terrorist watchlist." This list includes the No-Fly List, which prevents individuals from boarding flights, and the Selectee List, which subjects individuals to enhanced security screening. Four plaintiffs claim they are on the Selectee List due to repeated enhanced screenings, while one plaintiff, Adis Kovac, claims he is on both the No-Fly List and the Selectee List. Each plaintiff sought redress through the Department of Homeland Security’s Traveler Redress Inquiry Program (TRIP), but only Kovac received confirmation of his No-Fly List status.The plaintiffs filed a lawsuit in the U.S. District Court for the Northern District of Texas against various federal agency heads, alleging violations of their constitutional rights and unlawful agency action under the Administrative Procedure Act (APA). The district court dismissed several claims, including due process and equal protection claims, and later dismissed Kovac’s No-Fly List claims as moot after he was removed from the list. The remaining APA claims were addressed at summary judgment, where the district court ruled that the agencies had statutory authority to maintain the watchlist and that the TRIP procedures were not arbitrary and capricious.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that the relevant federal agencies have clear statutory authority to create, maintain, and use the watchlist for screening airline passengers. The court found that the statutory framework, including the Aviation and Transportation Security Act, the Homeland Security Act, and subsequent legislation, provided unambiguous authority for the watchlist. The court did not address whether the major questions doctrine applied, as the statutory authority was clear. The court also concluded that the plaintiffs lacked standing to challenge the watchlist’s use in contexts unrelated to airport security. View "Kovac v. Wray" on Justia Law

Ming Zheng, a drilling field engineer, suffered a work-related injury to her right ankle while attempting to disassemble a tool string. She reported the injury and received workers' compensation benefits. Approximately a year later, Zheng sought additional benefits for an injury to her left ankle and requested preauthorization for surgery on her right ankle. The Wyoming Department of Workforce Services, Workers' Compensation Division, denied these requests, finding the treatments were not related to her original work injury. The Division also discontinued her temporary total disability benefits after she received a 0% impairment rating.The Wyoming Medical Commission upheld the Division's denial of benefits and discontinuation of temporary total disability benefits after a contested case hearing. The Commission found that Zheng failed to prove the requested treatments for her left ankle were related to her compensable work injury and that the surgery on her right ankle was necessary. The district court affirmed the Medical Commission's decision.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The Court held that substantial evidence supported the Medical Commission's findings that Zheng's left ankle issues were not related to her work injury and that the requested surgery on her right ankle was not necessary. The Court also found that the Medical Commission did not act arbitrarily or capriciously in admitting an addendum to Dr. Orth's independent medical evaluation, as Zheng had the opportunity to cross-examine Dr. Orth and present rebuttal evidence. The Court concluded that the Medical Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "Zheng v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

The Environmental Protection Agency (EPA) updated its regulations to ensure that the transportation fuel mix in the United States contains the required amounts of renewable fuel. The new regulations specifically address biogas-derived renewable fuel, implementing a more structured process to prevent fraud and error. The Coalition for Renewable Natural Gas, representing industry stakeholders, petitioned to overturn these changes, arguing that the new rules were too rigid and burdensome.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The Coalition argued that the EPA lacked authority to regulate biogas producers and that the new requirements were arbitrary and capricious. They also claimed procedural violations in the rulemaking process. The EPA defended its regulations, stating that they were necessary to ensure compliance with renewable fuel standards and to prevent fraud and double counting.The Court of Appeals found that the EPA acted within its authority under the Clean Air Act to regulate biogas producers and that the new rules were reasonable and supported by substantial evidence. The court also held that the EPA had followed proper procedures in adopting the rule. The court denied the Coalition's petition for review, upholding the EPA's updated regulations. The main holding was that the EPA's modifications to the biogas-derived renewable fuel regulations were reasonable and necessary to ensure compliance with renewable fuel standards and to prevent fraud. View "Coalition for Renewable Natural Gas v. EPA" on Justia Law

Tenaska Clear Creek Wind, LLC ("Clear Creek") sought to generate wind energy for sale in parts of Missouri, southeast Iowa, and northeast Oklahoma. Clear Creek challenged the Federal Energy Regulatory Commission's (FERC) decision to allow Southwest Power Pool, Inc. (SPP) to assign over $100 million in upgrade costs to Clear Creek for its wind turbine project. Clear Creek argued that FERC's decision was arbitrary, capricious, and contrary to precedent.Initially, Clear Creek submitted an interconnection request to Associated Electric Cooperative, Inc. (AECI) and requested Network Resource Interconnection Service (NRIS). AECI identified SPP and Midcontinent Independent System Operator, Inc. (MISO) as potentially affected systems. SPP conducted several studies, initially estimating upgrade costs at $31.2 million, which later fluctuated significantly. Clear Creek began construction based on initial studies but faced a restudy by SPP, which increased the estimated costs to $763 million, later adjusted to $102 million. Clear Creek filed a complaint with FERC, which partially granted and partially denied the complaint, requiring SPP to restudy the project using updated models. The restudy resulted in $88 million in upgrade costs.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld FERC's orders, finding that SPP's methodology for assigning upgrade costs was consistent with the "but for" cost allocation principle and not arbitrary or capricious. The court also found that Clear Creek's downgrade to Energy Resource Interconnection Service (ERIS) did not moot the case, as Clear Creek retained the right to re-open the matter if it prevailed. The court concluded that FERC's decision was based on reasoned decision-making and substantial evidence, denying Clear Creek's petitions for review. View "Tenaska Clear Creek Wind, LLC v. FERC" on Justia Law

T.W., a Harvard Law School graduate with disabilities, sued the New York State Board of Law Examiners for denying her requested accommodations on the New York State bar exam in 2013 and 2014. She alleged violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. T.W. claimed that the Board's actions caused her to fail the bar exam twice, resulting in professional and financial harm.The United States District Court for the Eastern District of New York initially denied the Board's motion to dismiss, finding that the Board had waived its sovereign immunity under the Rehabilitation Act. However, the United States Court of Appeals for the Second Circuit reversed this decision, holding that the Board was immune from suit under Section 504. On remand, the district court granted the Board's motion to dismiss T.W.'s Title II claim, ruling that the Board was an "arm of the state" and entitled to sovereign immunity. The court also held that Title II did not abrogate the Board's sovereign immunity for money damages and that T.W. could not seek declaratory and injunctive relief under Ex parte Young.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the Board is an arm of the state and thus entitled to sovereign immunity. It further concluded that Title II of the ADA does not validly abrogate sovereign immunity in the context of professional licensing. Additionally, the court found that the declaratory relief sought by T.W. was retrospective and therefore barred by the Eleventh Amendment. The court also ruled that the injunctive relief sought by T.W. was not sufficiently tied to an ongoing violation of federal law, making it unavailable under Ex parte Young. Consequently, the court affirmed the dismissal of T.W.'s claims for compensatory, declaratory, and injunctive relief. View "T.W. v. New York State Board of Law Examiners" on Justia Law

A state trooper brought his patrol vehicle to a car dealership for service, accompanied by his canine, Diesel. During the visit, Diesel attacked and injured an employee, Cristina Berrier, without provocation. Berrier suffered serious injuries and subsequently sued the Minnesota State Patrol, alleging negligence and later indicating her intention to pursue a claim under Minnesota’s strict liability dog-bite statute, Minn. Stat. § 347.22.The district court denied the State Patrol’s motion to dismiss, concluding that Berrier’s complaint sufficiently pleaded her statutory claim and that the dog-bite statute waived sovereign immunity. The State Patrol appealed, and the Minnesota Court of Appeals reversed, holding that the State Patrol was immune from suit under the doctrine of sovereign immunity. The appellate court did not address whether Berrier adequately pleaded her statutory dog-bite claim.The Minnesota Supreme Court reviewed the case to determine if the dog-bite statute waived sovereign immunity. The court concluded that the language of Minn. Stat. § 347.22, which imposes liability on the "owner" of a dog, was sufficiently plain, clear, and unmistakable to waive sovereign immunity. The court emphasized that the statute’s broad application to any dog owner, including state entities, served the public policy interest of protecting individuals from dog attacks and ensuring their full recovery. Consequently, the court reversed the appellate court’s decision and remanded the case for further proceedings. View "Hennesy vs. Minnesota State Patrol" on Justia Law

Healthy Blue, a vendor, submitted a proposal to operate Nebraska’s Medicaid managed care program but was not selected. After its bid protest and request for reconsideration were denied by the Nebraska Department of Health and Human Services (DHHS), Healthy Blue filed a lawsuit in the district court for Lancaster County against state officials and the winning bidders. Healthy Blue sought declaratory and injunctive relief under the Uniform Declaratory Judgments Act (UDJA), claiming DHHS acted unlawfully in awarding the contracts.The district court overruled the state officials' motion to dismiss, which argued that Healthy Blue lacked standing as a taxpayer and that the claim was barred by sovereign immunity. The court found that Healthy Blue adequately pled taxpayer standing and that the claim was not barred by sovereign immunity because it sought relief from an invalid act by public officers. The state officials then moved for summary judgment, reiterating their sovereign immunity argument. The district court denied this motion, maintaining that the claim was an official-capacity suit not barred by sovereign immunity.The Nebraska Supreme Court reviewed the case. The court held that the state officials' motion for summary judgment was not based on the assertion of sovereign immunity, as they did not appeal the district court's ruling that the claim was an official-capacity suit. The court emphasized that standing and sovereign immunity are distinct jurisdictional concepts and that the question of standing can be reviewed on appeal of a final order without being effectively lost. Consequently, the Nebraska Supreme Court dismissed the appeal for lack of jurisdiction. View "Community Care Health Plan of Nebraska, Inc. v. Jackson" on Justia Law

A group of plaintiffs, including several states and corporations, challenged a Department of Labor rule that allowed ERISA fiduciaries to consider environmental, social, and governance (ESG) factors when making investment decisions if those factors equally serve the financial interests of the plan. This rule was issued following an executive order by President Biden, which counteracted a previous Trump-era rule that prohibited considering non-pecuniary factors in investment decisions.The United States District Court for the Northern District of Texas upheld the Department of Labor's rule, relying on the Chevron deference doctrine, which allows courts to defer to a federal agency's interpretation of ambiguous statutory language. The district court concluded that the rule was not "manifestly contrary to the statute" after affording the Department the deference due under Chevron.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which overruled Chevron, thus eliminating the deference previously given to agency interpretations. Given this significant change in the legal landscape, the Fifth Circuit vacated the district court's judgment and remanded the case for reconsideration in light of the new Supreme Court decision. The appellate court emphasized the importance of allowing the district court to reassess the merits without the Chevron framework, ensuring that the lower court's independent judgment is applied to the statutory interpretation of ERISA. View "State of Utah v. Su" on Justia Law