Justia Government & Administrative Law Opinion Summaries

The case involves Nicholas Sterry, an inmate at the Moose Lake Correctional Facility, who filed a lawsuit against the Minnesota Department of Corrections (DOC) and Correctional Officer Ashley Youngberg. Sterry alleged that Youngberg sexually assaulted and harassed him while he was working in the prison kitchen. The DOC was aware of Youngberg's history of harassment but had not disciplined her prior to the incidents involving Sterry. Sterry's lawsuit included claims of battery, intentional and negligent infliction of emotional distress, and negligence under a theory of vicarious liability.The district court dismissed Sterry's claims, concluding that the DOC was immune from the suit under the Minnesota State Tort Claims Act because Youngberg was not acting within the scope of her employment when the alleged assault occurred. Sterry appealed this decision, and the court of appeals reversed the district court's ruling. The court of appeals found that Sterry's complaint alleged sufficient facts to survive the motion to dismiss, as it was consistent with common law principles of vicarious liability applicable to private employers.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court held that a state employer could be held vicariously liable for an employee’s intentional tort under the Minnesota State Tort Claims Act if the tort is related to the duties of the employee and occurs within work-related limits of time and place. The court also found that Sterry's complaint alleged sufficient facts to survive the DOC's motion to dismiss. The court concluded that Sterry's claim could allow a jury to find that Youngberg was acting within the scope of her employment when the alleged assault occurred, under circumstances where the DOC would be liable under common law for vicarious liability. View "Sterry v. Minnesota Department of Corrections" on Justia Law

The case involves a dispute over the allocation of water from the Rio Grande River among the states of Texas, New Mexico, and Colorado. The Rio Grande Compact, an interstate agreement, governs the equitable distribution of the river's waters among these states. In 2013, Texas sued New Mexico and Colorado, alleging that excessive groundwater pumping in New Mexico was depleting the river's water supply intended for Texas, in violation of the Compact. The United States sought to intervene, asserting its own interests in the Compact's enforcement due to its operation of the Rio Grande Project, an irrigation system in southern New Mexico.In previous proceedings, the Supreme Court allowed the United States to intervene, recognizing its distinct federal interests in the Compact. The Court noted that the Compact was intertwined with the United States' operation of the Rio Grande Project and that the federal government had an interest in ensuring New Mexico complied with its obligations under the Compact.Texas and New Mexico proposed a consent decree to resolve the case, which would establish a methodology for determining each state's allocation of the river's waters. However, the United States opposed the proposed consent decree, arguing that it would dispose of its claims that New Mexico's groundwater pumping was violating the Compact.The Supreme Court of the United States agreed with the United States, holding that parties who choose to resolve litigation through settlement may not dispose of the claims of a third party without that party's agreement. The Court found that the United States still had the same claims it did in 2018, backed by the same unique federal interests. The Court concluded that the proposed consent decree would settle all parties' Compact claims and, in the process, cut off the United States' requested relief as to New Mexican groundwater pumping. As such, the Court denied the motion to enter the consent decree. View "Texas v. New Mexico" on Justia Law

A group of individuals and businesses challenged the Affordable Care Act's requirement for private insurers to cover certain types of preventive care, including contraception, HPV vaccines, and drugs preventing HIV transmission. The plaintiffs argued that the mandates were unlawful because the agencies issuing them violated Article II of the Constitution, as their members were principal officers of the United States who had not been validly appointed under the Appointments Clause. The district court mostly agreed, vacating all agency actions taken to enforce the mandates and issuing both party-specific and universal injunctive relief.The United States Court of Appeals for the Fifth Circuit agreed that the United States Preventive Services Task Force, one of the challenged administrative bodies, was composed of principal officers who had not been validly appointed. However, the court found that the district court erred in vacating all agency actions taken to enforce the preventive-care mandates and in universally enjoining the defendants from enforcing them. The court also held that the Secretary of the Department of Health and Human Services had not validly cured the Task Force’s constitutional problems.The court affirmed in part, reversed in part, and remanded the case for further proceedings. The court did not rule on the plaintiffs' challenges against the other two administrative bodies involved in the case, the Advisory Committee on Immunization Practices and the Health Resources and Services Administration, reserving judgment on whether the Secretary had effectively ratified their recommendations and guidelines. View "Braidwood Mgmt v. Becerra" on Justia Law

The case involves Hahnenkamm, LLC and the United States Forest Service. Hahnenkamm sold a parcel of land to the Forest Service. The purchase price was based on an appraisal that was supposed to comply with the Uniform Appraisal Standards for Federal Land Acquisitions, also known as the Yellow Book. Hahnenkamm later sued the Forest Service, claiming that the appraisal did not comply with the Yellow Book and was not independent, thus breaching the purchase agreement.The United States Court of Federal Claims found in favor of Hahnenkamm, ruling that the Forest Service had breached the agreement by not supporting the purchase price with an independent, Yellow Book-compliant appraisal. The court rejected the government's defenses of waiver and equitable estoppel and awarded damages to Hahnenkamm.The United States Court of Appeals for the Federal Circuit partially reversed the lower court's decision. The appellate court found that Hahnenkamm could not have reasonably relied on the contractual representation that the appraisal was independent. However, the court remanded the case back to the lower court for further proceedings to determine whether Hahnenkamm reasonably relied on the representation that the appraisal was Yellow Book-compliant. The court also remanded the lower court's rejection of the equitable estoppel defense.On cross-appeal, Hahnenkamm argued that the lower court erred in its damages determination. The appellate court affirmed the lower court's damages determination, finding no abuse of discretion in its analysis. View "HAHNENKAMM, LLC v. US " on Justia Law

The case involves Husky Marketing & Supply Company and Phillips 66 Company, two customers of a crude-oil pipeline, who petitioned for review of orders issued by the Federal Energy Regulatory Commission (FERC) approving the pipeline’s application to charge market-based rates for its shipping services. The petitioners argued that the Commission adopted an arbitrary and capricious definition of the relevant geographic destination market for the pipeline’s services when analyzing whether it had market power.Previously, the matter was referred to an administrative law judge (ALJ) who, after an evidentiary hearing, found the correct destination market was the narrower Wood River market advanced by Husky and Phillips, rather than the broader St. Louis BEA Economic Area advanced by Marathon. Both Marathon and the Petitioners filed exceptions to the ALJ’s decision. The Commission unanimously reversed the ALJ’s decision and concluded the correct geographical destination market was Wood River together with Patoka, Illinois.The United States Court of Appeals for the District of Columbia Circuit reviewed the FERC’s orders under the “arbitrary and capricious” standard. The court held that the FERC did not act arbitrarily or capriciously when it concluded Wood River and Patoka together, rather than Wood River alone, represent the area in which a shipper may rationally look for transportation service. The court also held that the FERC was not required to perform any additional empirical analysis in this case. Therefore, the petitions for review were denied. View "Husky Marketing and Supply Company v. FERC" on Justia Law

The case involves an appeal by Marmen Inc., Marmen Énergie Inc., Marmen Energy Co., the Government of Québec, and the Government of Canada against a decision by the U.S. Department of Commerce. The Department of Commerce had imposed countervailing duties on imports of certain utility scale wind towers from Canada, arguing that the Canadian government had provided illegal subsidies to the producers and exporters of these towers.The case was initially reviewed by the United States Court of International Trade, which upheld the Department of Commerce's decision. The appellants then appealed to the United States Court of Appeals for the Federal Circuit.The appellants argued that the Department of Commerce had erred in its assessment of three government programs and its computation of the sales denominator used to calculate the subsidy rate. They contended that the subsidy rate should have been de minimis, meaning it was too trivial or minor to merit consideration.The Court of Appeals for the Federal Circuit affirmed the judgment of the U.S. Court of International Trade, ruling that the Department of Commerce's determination was supported by substantial evidence and was in accordance with the law. The court rejected the appellants' arguments, finding that the Department of Commerce had reasonably determined that the auditor's adjustment was unreliable, and that the three subsidy programs at issue did provide countervailable subsidies. View "GOVERNMENT OF QUEBEC v. US " on Justia Law

This case involves a dispute over the interpretation of a statute that regulates healthcare providers participating in the federal Medicaid program. The State of Texas, acting through the Attorney General, sought to enforce a statute that imposes penalties on a provider who submits a claim for payment and knowingly fails to indicate the type of professional license and the identification number of the person who actually provided the service. The defendant, a dentist, argued that the statute only applies if a claim fails to indicate both the license type and the identification number of the actual provider.Previously, the trial court granted the State's motion for partial summary judgment and denied the defendant's motion. The court rendered a final judgment awarding the State more than $16,500,000. The defendant appealed, and the court of appeals affirmed the trial court's judgment, except for the amount of attorney’s fees and expenses.The Supreme Court of Texas reversed the lower courts' decisions. The court agreed with the defendant's interpretation of the statute. The court held that the statute applies only if a claim fails to indicate both the license type and the identification number of the actual provider. The court found that the 1,842 claims at issue did indicate the actual providers’ license type, so they did not constitute an unlawful act under the statute. The court rendered judgment in the dentist’s favor. View "MALOUF v. THE STATE OF TEXAS EX RELS. ELLIS AND CASTILLO" on Justia Law

The case involves Image API, LLC, a company that provided services to the Texas Health and Human Services Commission (HHSC) from 2009 to 2015. Image's job was to manage a processing center for incoming mail related to Medicaid and other benefits programs. The agreement between the parties stated that HHSC would compensate Image using its “retrospective cost settlement model”. In 2016, HHSC notified Image that an independent external firm would conduct an audit of Image’s performance and billing for the years 2010 and 2011. The audit concluded that HHSC had overpaid Image approximately $440,000 in costs relating to bonuses, holiday pay, overtime, and other unauthorized labor expenses. HHSC then sought to recoup the overpayments by deducting from payments on Image’s invoices.The trial court granted HHSC’s motion for summary judgment and signed a final judgment for the commissioner. The court of appeals reversed the trial court’s judgment and dismissed Image’s entire suit for want of jurisdiction. Image sought review.The Supreme Court of Texas held that Image is a Medicaid contractor under Section 32.0705(a), and that the deadline in Section 32.0705(d) for auditing HHSC’s Medicaid contractors is mandatory. However, the court ruled that HHSC’s failure to meet the deadline does not preclude it from using the result of the audit or pursuing recoupment of overcharges found in the audit. The court affirmed the part of the court of appeals’ judgment dismissing Image’s claims arising from the 2016 audit for lack of jurisdiction, reversed the part of the judgment dismissing the remainder of Image’s suit, and remanded to the trial court for further proceedings. View "IMAGE API, LLC v. YOUNG" on Justia Law

The case revolves around Katherine Harris, who was convicted for aggravated DUI. While driving with a blood-alcohol concentration (BAC) twice the legal limit, Harris crashed into a deputy sheriff and his patrol vehicle, causing severe injuries to the deputy. Before trial, Harris requested public funds to hire her own experts, a toxicologist and an accident reconstructionist, to counter the State’s evidence. However, her blood sample, which she had not requested to be preserved, had been destroyed according to routine procedure nine months after testing. The judge denied her requests for expert funding, finding them broad and theoretical, and Harris failed to articulate concrete reasons how these proposed independent experts would specifically assist her defense.In Mississippi, the discretion to grant or deny an indigent defendant funds to retain an independent expert lies with the trial court. The court found that Harris failed to articulate how her own experts would actually assist her defense. Furthermore, the State’s case did not rely exclusively on these two experts and her BAC. The State called additional witnesses who established the patrol car was clearly visible with its blue lights flashing, and multiple other vehicles successfully passed the patrol car before Harris slammed into it. Witnesses also testified Harris smelled like alcohol, failed a field sobriety test, admitted she had been drinking, and tested positive for alcohol on a portable breathalyzer at the scene.The Supreme Court of Mississippi affirmed Harris’s conviction and sentence, discerning no abuse of discretion in the judge’s denial of Harris’s request for expert funds. Based on the overwhelming evidence supporting Harris’s aggravated DUI conviction, the judge’s discretionary denial, even if erroneous, was not so prejudicial as to render her trial fundamentally unfair. View "Harris v. State of Mississippi" on Justia Law

Randal Hall filed a civil rights case against Officer Travis Trochesset and the City of League City, Texas, alleging constitutional violations following his arrest for interference with a police investigation. The incident began when Hall's wife was involved in a minor car accident. The other driver reported the incident as a hit-and-run, leading to an investigation by Officer Trochesset. When Trochesset arrived at the Halls' home to gather information, Hall, who was not present, instructed his wife over the phone not to provide the requested information to Trochesset. As a result, Trochesset obtained an arrest warrant for Hall for interfering with public duties.The United States District Court for the Southern District of Texas dismissed Hall's suit, ruling in favor of Trochesset and the City of League City. Hall appealed the decision.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court found that probable cause existed for Hall's arrest, as Hall had interfered with Trochesset's investigation. The court also applied the independent intermediary doctrine, which states that an officer who presents all relevant facts to an impartial intermediary (in this case, a justice of the peace) is not liable if the intermediary's independent decision leads to an arrest. The court found that Trochesset had not withheld any relevant information from the justice of the peace. Furthermore, the court ruled that Hall failed to establish that Trochesset violated the Fourth or Fourteenth Amendments. The court also dismissed Hall's claim against the City of League City, as there was no constitutional violation by Trochesset, and Hall failed to identify an official policy or custom that led to the alleged violation. The court rejected Hall's argument to discontinue the application of the qualified immunity doctrine, stating that it is bound by the Fifth Circuit rule of orderliness to follow established precedent. View "Hall v. Trochessett" on Justia Law