Justia Government & Administrative Law Opinion Summaries

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

A former deputy executive director of a bi-state agency, the Port Authority of New York and New Jersey, was prosecuted in connection with the “Bridgegate” scandal. Although convicted, his convictions were ultimately vacated and the indictment dismissed. Having incurred approximately $4 million in legal expenses, he sought indemnification from the Port Authority under its bylaws, which provide for reimbursement of legal costs upon acquittal or dismissal of criminal charges, subject to certain notice and procedural requirements.After the Port Authority denied his request for indemnification, he commenced suit in New York state court. The Port Authority removed the case to the United States District Court for the Southern District of New York. There, the Port Authority argued that the court lacked subject matter jurisdiction because the plaintiff had not satisfied a condition precedent for suit—specifically, timely delivery of the judgment of acquittal per the bylaws—meaning that the necessary waiver of sovereign immunity had not occurred. The district court agreed, dismissing the case for lack of subject matter jurisdiction and subsequently denying leave to amend the complaint as futile, finding that the plaintiff had failed to plead compliance with the condition precedent.The United States Court of Appeals for the Second Circuit reviewed the dismissal. It held that the Port Authority does not possess state sovereign immunity from suit in federal court, as established by the Supreme Court in Hess v. Port Authority Trans-Hudson Corp., and therefore a failure to plead waiver of sovereign immunity does not deprive the federal court of subject matter jurisdiction. The court vacated the district court’s judgment and remanded for further proceedings, overruling prior circuit precedent to the contrary. The court also vacated the denial of leave to amend, clarifying that compliance with contractual or statutory conditions is an affirmative defense, not a jurisdictional prerequisite. View "Baroni v. Port Authority of New York and New Jersey" on Justia Law

An employee of a company specializing in training security officers raised concerns to management about unsafe working conditions, including the handling of weapons and a hazardous firing range where bullet ricochets had resulted in injuries. The employee, along with other instructors, formally complained to supervisors about these dangers, especially during the onset of the COVID-19 pandemic, when he also questioned restrictions on personal protective equipment. After voicing these safety concerns, the employee was suspended and later terminated, allegedly for insubordination.The employee filed a charge with the Regional Director of the National Labor Relations Board (NLRB), asserting that his termination was unlawful retaliation for engaging in protected concerted activity under the National Labor Relations Act (NLRA). After investigation, an NLRB administrative law judge (ALJ) held a hearing and determined that the employee was not a managerial employee and was therefore protected by the NLRA. The ALJ found that the primary reason for the suspension and termination was the employee’s repeated advocacy regarding workplace safety, not insubordination. The ALJ concluded that the employer had committed unfair labor practices. The employer appealed, and the NLRB affirmed the ALJ’s decision with minor modifications.The United States Court of Appeals for the Fourth Circuit reviewed the NLRB’s order. Applying the substantial evidence standard, the court held that the Board’s conclusion—that the employee was not a managerial employee—was supported by the record. The court found that the employee lacked authority to formulate or implement management policy and did not possess the discretion characteristic of managerial status. Therefore, the employee was entitled to the NLRA’s protections. The court granted the NLRB’s application for enforcement of its order and denied the employer’s cross-petition for review. View "National Labor Relations Board v. Constellis, LLC" on Justia Law

A licensed horse trainer was involved in a dispute with a state racing steward after the steward refused to reinstate an assistant trainer’s license. Following a heated phone conversation in which the trainer criticized the steward, the state agency regulating horse racing initiated a disciplinary action against the trainer, alleging conduct that could negatively reflect on the integrity of horse racing. A panel of stewards found a violation and issued a conditional fine. The trainer appealed for a de novo administrative hearing but later withdrew the appeal and instead filed a lawsuit in district court, claiming the agency’s actions were a retaliatory violation of his state constitutional rights under the New Mexico Civil Rights Act.The district court denied the agency’s motion for summary judgment, holding that judicial immunity was not available to the public body under the Civil Rights Act. On interlocutory appeal, the New Mexico Court of Appeals reversed, finding that the statutory language preserved judicial immunity as a defense and that the agency was entitled to quasi-judicial immunity based on its role and the nature of the proceedings, directing entry of summary judgment for the agency.The Supreme Court of the State of New Mexico reviewed whether judicial immunity is a defense available to a public body sued under the New Mexico Civil Rights Act. The Court held that judicial immunity does apply to public bodies in this context, reasoning that the doctrine’s policy goals—protecting independent decision-making and the integrity of judicial or quasi-judicial processes—apply to both individuals and government entities. However, the Court found the record insufficient to decide whether the agency’s conduct warranted immunity under this standard and remanded the matter to the district court for further proceedings consistent with its clarified framework. The Court affirmed in part and reversed in part the Court of Appeals’ decision. View "Bolen v. N.M. Racing Commission" on Justia Law

Several defendants facing prosecution for federal criminal charges in the District of New Jersey challenged the authority of Alina Habba to serve as Acting U.S. Attorney. They argued that her appointment violated federal law governing who may serve as an acting official in positions requiring presidential appointment and Senate confirmation. Habba’s appointment followed a series of administrative moves: after the previous U.S. Attorney resigned, the First Assistant U.S. Attorney initially assumed the acting duties under the Federal Vacancies Reform Act (FVRA). The Attorney General later appointed interim U.S. Attorneys, including Habba, under a statute specific to U.S. Attorneys, and after Habba’s interim term expired, she was made a Special Attorney and designated First Assistant, with the government contending this made her eligible for acting service under the FVRA.The United States District Court for the District of New Jersey, presided over by Judge Matthew W. Brann, denied the defendants’ motions to dismiss their indictments but granted their motions to disqualify Habba from participating in the prosecutions. The court found that Habba was not lawfully serving as Acting U.S. Attorney under the governing statutes. The government appealed the disqualification order.The United States Court of Appeals for the Third Circuit reviewed the District Court's order under the collateral order doctrine. The Third Circuit held that only the First Assistant in place at the time of the vacancy is eligible for automatic acting service under the FVRA and that Habba, having been nominated for the permanent U.S. Attorney position, was barred from acting service by the FVRA’s nomination restriction. The court also held that the Attorney General’s broad delegation of all U.S. Attorney powers to Habba was prohibited by the FVRA’s exclusivity provision. The Third Circuit affirmed the District Court’s order disqualifying Habba from the prosecutions. View "USA v. Giraud" on Justia Law

A California nonprofit organization focused on preventing deceptive environmental claims filed a lawsuit against a manufacturer of feminine hygiene products. The organization alleged that the manufacturer labeled and advertised certain products, including period underwear, pads, and panty liners, as “organic” or “made with organic cotton” in violation of the California Organic Food and Farming Act (COFFA). The complaint stated that these products contained less than the minimum required percentage of certified organic materials and included nonagricultural and nonorganically produced components not permitted under state or federal organic standards.The case was first heard in the Alameda County Superior Court. The manufacturer moved for judgment on the pleadings, arguing that COFFA applies only to agricultural products, cosmetics, and pet food—not to personal care products such as feminine hygiene items. The Superior Court agreed with the manufacturer and granted judgment on the pleadings, concluding that COFFA did not govern the products in question. The nonprofit timely appealed that decision.The Court of Appeal of the State of California, First Appellate District, Division Two, reviewed the case de novo. The appellate court held that COFFA applies broadly to all products sold as “organic” or containing “organic” materials in California, unless specifically exempted, and that the statute’s plain language encompasses feminine hygiene products. The court found no basis for an implied exception for personal care products and determined that the trial court erred in its interpretation. Therefore, the appellate court reversed the trial court’s judgment, clarifying that COFFA’s standards and labeling requirements apply to the manufacturer’s products at issue. View "Environmental Democracy Project v. Rael" on Justia Law

A city in California owned a downtown parking garage known as Garage 5, which was in poor condition and underutilized according to studies conducted in 2019 and 2022. The city had previously adopted a housing plan to identify public land suitable for housing development. In public meetings and study sessions throughout 2021 and 2022, city staff and consultants presented data showing declining demand for public parking and the high cost of necessary repairs to Garage 5. After further study and public comment, the city’s council passed a resolution in December 2022 declaring Garage 5 to be surplus land under the Surplus Land Act, provided that any future development retain at least 75 public parking spaces.The owner of nearby properties, Airport Business Center, filed a petition for writ of mandate and complaint for declaratory relief in Sonoma County Superior Court. The petitioner argued the city had violated the Surplus Land Act by declaring the garage surplus while there was still an ongoing need for public parking and contended that the city’s findings were not supported by the evidence. The Superior Court denied the petition, finding the city’s actions were not arbitrary or capricious, and that there was substantial evidentiary support for the resolution. A temporary stay was granted pending appeal, but the Court of Appeal denied a request for further stay.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. It held that the Surplus Land Act’s requirement that property be “not necessary for the agency’s use” allows a city to designate property as surplus if it is not indispensable for agency operations, even if the property serves a public purpose like parking. The evidence supported the city’s determination, and the findings in the resolution satisfied statutory requirements. The appellate court affirmed the judgment, awarding costs to the city. View "Airport Business Center v. City of Santa Rosa" on Justia Law

A property owner in Los Angeles obtained a density bonus from the city in 2005, allowing him to build one additional housing unit beyond what zoning would otherwise permit, in exchange for agreeing to rent one of the units to low-income households for at least 30 years. This agreement was formalized and recorded against the property in 2006. The owner had previously taken out a mortgage, and the lender recorded its deed of trust against the property in 2005. After the owner defaulted, the lender foreclosed on the property in 2013. Several years later, new owners purchased the property, allegedly unaware of the recorded agreement requiring the low-income rental restriction.Following a notice from the City demanding compliance with the affordable housing agreement, the new owners filed suit in the Superior Court of Los Angeles County, seeking quiet title and declaratory relief. They argued that the affordable housing agreement, recorded after the original deed of trust, was a junior encumbrance extinguished by the foreclosure. The City countered that the agreement was a condition of a building permit and survived foreclosure. The trial court sustained the City’s demurrer without leave to amend, finding that the agreement was a covenant running with the land and survived foreclosure.On appeal, the California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s judgment. The appellate court held that the affordable housing agreement was equivalent to a “condition attached to a permit” under Government Code section 65009, subdivision (c)(1)(E), and thus survived foreclosure. Permit conditions that have not been timely challenged run with the land and remain enforceable against successor owners, even those who acquire the property through foreclosure. The court concluded that the plaintiffs failed to state a valid claim and were not entitled to amend their complaint. View "Rodriguez v. City of Los Angeles" 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