Justia Government & Administrative Law Opinion Summaries

The case revolves around Thomas E. Hennig, Jr., who was discharged from his job at Money Metals Exchange, L.L.C. after making a controversial comment on the company's instant messaging system. Hennig referred to himself as his employer’s “good little Nazi” in a joke about enforcing the company’s time clock rules. After his termination, Hennig applied for unemployment benefits, but his application was denied by the Idaho Department of Labor (IDOL) on the grounds that he was discharged for misconduct connected with his employment. Hennig appealed this decision to the Idaho Industrial Commission, which upheld the IDOL's decision.Hennig then appealed to the Supreme Court of the State of Idaho, arguing that the Commission’s decision was unsupported by competent and substantial evidence. He contended that his use of the term "Nazi" was not objectively unprofessional and that the company had tolerated racist remarks from another employee. The Supreme Court of Idaho reversed the Commission’s decision and remanded the case for further proceedings. The court found that the Commission had failed to properly analyze whether the company's expectations of Hennig's behavior were objectively reasonable, given evidence that it had tolerated racist comments from another co-worker and then promoted him to a supervisory position. The court also found that the Commission had failed to consider Hennig's claim that the company had encouraged his unorthodox humor. View "Hennig v. Money Metals Exchange" on Justia Law

Domingo Musquiz, a former rail industry employee, petitioned for review of a decision by the U.S. Railroad Retirement Board (RRB). The RRB had adopted a hearing officer's finding that Musquiz was at fault for an overpayment of his reduced-age annuity under the Railroad Retirement Act (RRA) and denied his request for a waiver or reduction of repayment of the overpayment and penalty. Musquiz had failed to report his re-employment and additional income to the RRB, leading to the overpayment.The RRB's decision was based on the fact that Musquiz had received a booklet of regulations, including reporting requirements, when he applied for his annuity. The RRB concluded that Musquiz should have known about his reporting duties and was at fault when he did not report his change in employment and additional outside income.The United States Court of Appeals for the Ninth Circuit agreed with the RRB that Musquiz was at fault for the overpayment that occurred from August 2012 to June 2, 2013. However, the court concluded that Musquiz was without fault for the RRB’s overpayment of his annuity from June 3, 2013, onward. The court reasoned that by then, the RRB had informed Musquiz that they had taken his outside earnings into account and adjusted his annuity payments.The court granted Musquiz's petition, vacated the RRB's decision, and remanded the case to the RRB for further proceedings. The court instructed the RRB to develop a factual record and determine whether recovery of the overpayment from June 3, 2013, onward would be contrary to the purpose of the RRA, against equity, or against good conscience. View "Musquiz V. United States Railroad Retirement Board" on Justia Law

In April 2018, Benjamin Evans was shot and killed by Police Deputy Brian Krook in Lake Elmo, Minnesota, after Evans knelt in a crosswalk with a loaded gun pointed at his own head. Following a criminal trial, Krook was acquitted of a second-degree manslaughter charge. Subsequently, Evans' father, William O. Evans, Jr., filed a civil lawsuit against Krook under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. Krook sought summary judgment based on qualified immunity, a defense unavailable when an officer uses deadly force against someone who does not pose an immediate threat of serious physical harm to another.The District Court for the District of Minnesota denied Krook's motion for summary judgment, citing genuine factual disputes over whether Evans' gun was ever pointed at the officers and whether Evans posed an immediate threat to them. Krook appealed this decision, challenging the denial of qualified immunity.The United States Court of Appeals for the Eighth Circuit, in reviewing the case, first addressed the question of jurisdiction. The court noted that it did not have jurisdiction to review the district court's determination regarding evidence sufficiency, i.e., what facts a party may or may not be able to prove at trial. The court's jurisdiction was limited to the purely legal question of whether the conduct that the district court found was adequately supported in the record violated a clearly established federal right.The court found that the availability of qualified immunity in this case hinged on whether Krook acted reasonably under the circumstances by shooting Evans because Evans either pointed his gun at another or otherwise wielded his gun in a menacing fashion. The court concluded that the inconclusive nighttime videos of Evans' actions did not clearly contradict the district court's factual determinations. Therefore, resolving the underlying factual dispute was beyond the court's limited review. As such, the court dismissed the appeal, stating it lacked the jurisdiction to resolve it. View "Evans v. Krook" on Justia Law

The case revolves around Larry Sapp, an Army veteran with a history of felony drug convictions, who was elected to the Sauk Village Board of Trustees in Illinois. However, his felony convictions came to the attention of the Cook County State’s Attorney’s Office, which used two Illinois statutes to remove him from his position. These statutes bar certain felons from holding public office. Sapp challenged the constitutionality of these statutes, arguing that they violated the Eighth Amendment's clauses on Cruel and Unusual Punishment and Excessive Fines by barring him from public service and depriving him of the income a career in public service would generate.The Cook County Circuit Court rejected Sapp's arguments, ruling that the statutes' enforcement did not violate the Eighth Amendment. The court held that Sapp was ineligible to serve as a Board Trustee and removed him from his position. Sapp then filed a federal lawsuit against Illinois Governor J.B. Pritzker and State’s Attorney Kimberly Foxx, seeking to bar the Cook County State’s Attorney from enforcing either statute against him in future elections. He reiterated his Eighth Amendment arguments and added a new one, claiming that enforcing the statutes against him would violate the Cruel and Unusual Punishment Clause.The United States Court of Appeals for the Seventh Circuit affirmed the dismissal of Sapp’s complaint. The court did not reach the merits of Sapp's constitutional arguments, instead ruling that they were foreclosed by Illinois principles of collateral estoppel and res judicata. The court held that Sapp's federal lawsuit arose from the same group of operative facts as the State’s Attorney’s quo warranto action in Cook County Court, and thus constituted the same "cause of action" under Illinois law. As a result, Sapp was barred from raising arguments in the federal suit that were available to him in the quo warranto action. View "Sapp v. Foxx" on Justia Law

The case involves the Union Leader Corporation (Union Leader) and the New Hampshire Department of Safety (Department). Union Leader sought to compel the Department to disclose records under the Right-to-Know Law, specifically records related to the response by New Hampshire State Police to the Sununu Youth Services Center (SYSC) on October 7 and 8, 2022. The Department refused to disclose the records, arguing that they were confidential law enforcement investigative records pertaining to juvenile delinquency.The Superior Court dismissed Union Leader's suit, siding with the Department. The court found that the requested records contained facts that underlie the basis for juvenile delinquency proceedings. Therefore, based on a previous decision in Petition of State of New Hampshire (Disclosure of Juvenile Records), the court concluded that the release of the records Union Leader requested was prohibited.The Supreme Court of New Hampshire reversed the lower court's decision and remanded the case. The Supreme Court found that the term "court records" in RSA 169-B:35 should not be read so expansively as to shield a broad category of otherwise public records from a request made pursuant to the Right to Know Law, even if that record is related to alleged unlawful conduct by unidentified minors. The court concluded that it is conceivable that information in the Department’s possession could answer Union Leader's questions without interfering with the rehabilitation of the minors against whom juvenile petitions were filed. It is also conceivable that responsive records could be redacted so as to ensure that their disclosure neither conflicts with nor compromises the rehabilitative purpose of RSA chapter 169-B. The case was remanded for the lower court to make those determinations. View "Union Leader Corp. v. N.H. Dep't of Safety" on Justia Law

The case revolves around a dispute between H. Cliff Page and the Portsmouth Redevelopment and Housing Authority (PRHA). Page owned a building in Portsmouth that shared a common wall with a building owned by PRHA. In 2014, PRHA demolished its building after the City of Portsmouth declared it an unlawful nuisance. Page claimed that the demolition was negligently performed and damaged his building. PRHA responded with a plea in bar, raising the defense of sovereign immunity.The circuit court held a hearing on the plea in bar and ruled in favor of PRHA, holding that sovereign immunity barred Page’s claim. The court found that the demolition of the property was implemented under the City of Portsmouth’s plan to address blight in the Downtown Portsmouth Historic District. The Court of Appeals affirmed the circuit court’s ruling, stating that PRHA’s immunity should be the same as that of the City of Portsmouth.However, the Supreme Court of Virginia disagreed with the lower courts' decisions. The court held that sovereign immunity does not shield PRHA from tort liability under the circumstances of this case. The court found that PRHA was acting in its proprietary capacity, similar to a private landowner, when it demolished the building. The court concluded that PRHA's obedience to the City’s Notice of Emergency Demolition was not an exercise of governmental discretion but a ministerial legal duty to perform a proprietary function. Therefore, the court reversed the decision of the Court of Appeals and remanded the case to the circuit court for further proceedings. View "Page v. Portsmouth Redevelopment & Housing Authority" on Justia Law

The case revolves around the Metropolitan Washington Airports Authority (the Authority), an entity jointly created by Virginia and the District of Columbia to manage the area's two airports. The Authority disputed the Virginia Department of Labor and Industry's (the Department) power to enforce its workplace safety laws against the Authority. The Department had levied a monetary penalty against the Authority following an accident that resulted in an employee's injury. The Authority contested the Department's power to enforce these penalties, arguing that it was not subject to Virginia workplace safety regulations due to its status as an interstate compact entity.The Department's adjudicator found that the Authority was subject to Virginia workplace safety regulations, a decision adopted by the Department's Commissioner. The Authority then sued the Commissioner in federal court seeking injunctive and declaratory relief. The district court ruled in favor of the Authority, reasoning that Virginia had surrendered its ability to exercise unilateral regulatory authority over the Authority's facilities when it created the Authority.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court agreed with the Authority that by jointly creating the Authority with the District, Virginia relinquished its control over the Authority except as otherwise provided in the Compact. The court rejected the Department's argument that the Compact expressly reserves its power to enforce Virginia’s workplace safety regulations against the Authority. The court also dismissed the Department's contention that it can enforce its workplace safety laws against the Authority because nothing in the Compact preempts Virginia law. View "Metropolitan Washington Airports Authority v. Pan" on Justia Law

The case revolves around the defendant, Maurice Williams, whose supervised release was revoked after evidence was presented that he sold fentanyl to a confidential informant (CI) during a controlled buy. Williams had previously pleaded guilty to charges of distributing crack cocaine and unlawful possession of a firearm. His supervised release was revoked in 2020 due to violation of his release conditions, and he was sentenced to an additional 18 months’ imprisonment, followed by two years of supervised release. In 2023, his supervised release was recommended for revocation again due to alleged violations including unlawful possession of a controlled substance and committing another crime.The United States District Court for the District of Kansas held a revocation hearing where the government introduced evidence of the controlled buy, including testimony from Kansas City Police Officers and a video of the controlled buy. The court found that Williams sold fentanyl and therefore committed a Grade A violation, but did not find a violation related to the firearm. The court revoked his term of supervised release and sentenced him to 24 months’ imprisonment.On appeal to the United States Court of Appeals for the Tenth Circuit, Williams argued that the district court erred by admitting evidence of the controlled buy without conducting an interest-of-justice balancing test under Federal Rule of Criminal Procedure 32.1(b)(2)(C) to determine whether the CI should have been required to be available for cross-examination at the hearing, and that the evidence was insufficient to show that he sold fentanyl. The Court of Appeals affirmed the district court's decision, stating that no balancing test was required because the court did not rely on any hearsay statements by the CI, and the evidence was sufficient to establish guilt by a preponderance of the evidence. View "United States v. Williams" on Justia Law

The Regents of the University of California (Regents) approved the construction of a new hospital at the University of California San Francisco (UCSF) Parnassus Heights campus. The Parnassus Neighborhood Coalition (the Coalition), a group of local property owners, sued to halt the construction, arguing it would violate local building height and bulk restrictions. The Regents countered that as a state entity, they were immune from local building and zoning regulations when engaging in governmental activities, such as constructing university buildings. The trial court disagreed, ruling that the question of whether the construction constituted a governmental or proprietary activity could not be resolved at this stage.The trial court concluded that the Regents' immunity depended on whether the proposed construction was a governmental or proprietary activity, a question of fact that could not be resolved on a demurrer. The court further concluded that the exemption only applies when a project is solely for educational purposes. The Regents petitioned for a writ of mandate to vacate the trial court’s order.The Court of Appeal of the State of California First Appellate District Division Three reviewed the case. The court held that the proposed hospital would facilitate the provision of clinical services, thereby advancing UCSF’s academic mission and the Regents’ educational purpose, which is a governmental activity. Therefore, the project falls within the Regents’ broad public purpose, and the Regents are exempt from the local regulations at issue. The court concluded that the demurrer should have been sustained and issued the writ of mandate. The court also ordered modifications to the published opinion filed on June 13, 2024, but there was no change in the judgment. View "Regents of the University of Calif. v. Super. Ct." on Justia Law

In a case involving the Pennsylvania Liquor Control Board (PLCB), the Supreme Court of Pennsylvania was asked to determine whether the PLCB is a "person" under Section 8303 of the Judicial Code and, if so, whether sovereign immunity bars mandamus damages sought under that provision. The case arose from the PLCB's failure to implement procedures to facilitate the direct shipment of special orders to customers, as required by law. The Commonwealth Court had issued a declaratory judgment to that effect and a writ of mandamus compelling the PLCB to comply. The Wine Vendors and Log Cabin subsequently applied for mandamus damages under Section 8303, which the PLCB contested, arguing that it was not a "person" under the statute and that sovereign immunity barred such damages.The Supreme Court of Pennsylvania held that the PLCB is a "person" within the meaning of Section 8303 and that sovereign immunity does not bar mandamus damages available under that provision. The court also held that attorneys’ fees awarded in relation to Section 8303 are not barred by sovereign immunity. The court affirmed the holdings of the Commonwealth Court and remanded for further proceedings. View "MFW WINE CO., LLC v. PENNSYLVANIA LIQUOR CONTROL BOARD" on Justia Law