Justia Government & Administrative Law Opinion Summaries

The case revolves around a dispute over a permit application to repair and maintain Imperial Gulch Road (IGR), which provides access to the property of the appellant, Jeffrey "Jae" Hill. The respondent, Blaine County, denied the permit application, concluding that it did not have the authority to issue the permit because it had previously declined to validate IGR. Hill filed a petition for judicial review of the Board’s decision.The district court affirmed the Board’s denial in part and vacated its decision in part. The court concluded that the Board did not validate IGR and therefore the Board lacked authority to issue the requested permit. However, the court remanded the matter back to the Board to determine if the Board had authority to issue the permit under a public easement theory. Hill appealed, arguing that the district court erred by determining that the Board had not validated IGR.The Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that the district court did not err when it affirmed the Board’s decision that it lacked authority to grant Hill’s permit because it had not validated IGR. The court found that Hill failed to establish that the Board’s decision denying his permit was arbitrary, capricious, or an abuse of discretion. The court did not disturb the district court’s order vacating the Board’s decision in part and remanding the matter to the Board for further proceedings. View "Hill v. Blaine County" on Justia Law

The case involves the State of Connecticut and the Connecticut State University Organization of Administrative Faculty, AFSCME, Council 4, Local 2836, AFL-CIO. The plaintiff, the state, sought to vacate an arbitration award reinstating a union member to his employment as the director of student conduct at a state university. The defendant union sought to confirm the award. The grievant’s employment had been terminated in connection with a domestic dispute involving his wife. The university conducted its own investigation and subsequently informed the grievant that his employment was being terminated as a result of his off-duty conduct. The union contested the grievant’s discharge, and an arbitration hearing was held. The arbitrator concluded that the university did not have just cause to terminate the grievant’s employment and ordered his reinstatement.The state contended that the award violated public policy. The trial court rendered judgment granting the state’s application to vacate the award and denying the union’s motion to confirm the award, from which the union appealed. The Supreme Court of Connecticut held that the state failed to demonstrate that enforcement of the arbitration award reinstating the grievant to his position of director of student conduct violated public policy. The court reversed the trial court’s judgment and remanded the case with direction to grant the union’s motion to confirm the award and to deny the state’s application to vacate the award. View "State v. Connecticut State University Organization of Administrative Faculty" on Justia Law

The case involves the Gardiner-Park County Water and Sewer District (District) and the Knight family (Knights). The Knights own a property in Gardiner, Montana, under which the District has a prescriptive easement for a sewer line. In 2016, a survey revealed that part of the Knights' house and porch was built within the easement and over the sewer line. The District requested the Knights to remedy the easement violation, but the parties failed to reach an agreement. Consequently, the District filed a lawsuit seeking a declaratory judgment that the Knights violated the District’s easements and caused damage to a retaining wall. The Knights counterclaimed, alleging that the District's Board Members had not taken and filed an oath of office, thus rendering any action they took invalid.The District Court of the Sixth Judicial District, Park County, granted a declaratory judgment in favor of the District and summary judgment in favor of the individual Board Members. The court held that the District’s Board Members were not legally required to file oaths of office and were immune from personal liability for any actions taken related to the Knights. The court also held a joint hearing on the District’s Motion for Declaratory Judgment and the individual Board Members’ Motion for Summary Judgment.The Supreme Court of the State of Montana affirmed the lower court's decision. The court concluded that there was no requirement for board members of a local water and sewer district to take and file an oath of office as they were not public officers of the state, nor members of the legislature or executive. The court also held that the Board Members were immune from suit in an action against the governmental entity for the same subject matter, even when oppression, fraud, or malice had been alleged. The court found no violation of the Knights' due process rights when the District Court entertained oral argument on a summary judgment motion and a declaratory judgment action at the same hearing. The case was remanded for the District Court to consider an award of attorney fees, if any, under the Declaratory Judgments Act. View "Gardiner-Park v. Knight" on Justia Law

This case involves a dispute between the City of Great Falls and the Board of Commissioners of Cascade County, Montana, over the interpretation of a 1975 interlocal agreement that established a consolidated City-County Health Board. The disagreement arose after the Montana Legislature enacted new laws in 2021 that changed the governance of local health boards. The County argued that the new laws required the County Commission to be the governing body of the Health Board, while the City maintained that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board.The District Court of the Eighth Judicial District ruled in favor of the City, finding that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board and that the Health Board was the "local governing body" referenced in the new laws. The County appealed this decision to the Supreme Court of the State of Montana.The Supreme Court affirmed the District Court's decision. It held that the District Court did not adjudicate a non-justiciable political question and correctly interpreted the 1975 agreement and the new laws. The Supreme Court found that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board and that the Health Board was the "local governing body" referenced in the new laws. The Court also held that the new laws did not moot the issues at stake in the case. View "City of Great Falls v. Cascade County Commissioners" on Justia Law

The case involves Jay Diamond, who was convicted of impersonating a federal officer in an attempt to avoid a speeding ticket and to avoid being arrested for falsely impersonating a federal officer. The incidents occurred when Diamond was pulled over for speeding and he told the officer that he was an air marshal. He presented a badge that read "United States Federal Air Marshal." However, upon investigation, it was found that Diamond was never employed as a federal air marshal or through the Transportation Security Administration (TSA).In the lower courts, Diamond argued that the government failed to present sufficient evidence to establish that he acted as a federal officer and that the district court erred in admitting evidence of his alleged prior bad acts and in instructing the jury. The district court denied Diamond's motion to exclude his ex-wife's testimony about his prior instances of impersonating a federal officer or military member. The court also denied Diamond's request for a jury instruction on the misdemeanor offense in 18 U.S.C. § 701, which Diamond argued was a lesser included offense of his alleged § 912 crime.In the United States Court of Appeals for the Eleventh Circuit, Diamond's convictions were affirmed. The court found that the evidence was sufficient to support Diamond’s § 912 convictions. The court also ruled that the district court did not abuse its discretion in admitting Diamond's ex-wife's testimony. Furthermore, the court found that 18 U.S.C. § 701 is not a lesser included offense of § 912, and therefore the district court did not err in refusing to give Diamond's requested § 701 instruction. View "United States v. Diamond" on Justia Law

Louis Frantzis, a U.S. Army veteran, appealed a decision by the Board of Veterans’ Appeals (Board) that denied his claim for an increased disability rating for his service-connected headaches. The Board's decision was made by a member who did not conduct the hearing, which Frantzis argued was a violation of 38 U.S.C. § 7102. He contended that the same Board member who conducts a hearing should also issue the resulting decision. The United States Court of Appeals for Veterans Claims (Veterans Court) affirmed the Board's decision, concluding that the Veterans Appeals Improvement and Modernization Act of 2017 (AMA) does not require the Board member conducting the hearing to also decide the appeal.The Veterans Court's decision was based on the removal of pre-AMA language in 38 U.S.C. § 7107(c) that required the same judge conducting the hearing to issue a final determination. The court also rejected the argument that 38 U.S.C. § 7102 supports the same judge requirement because its language did not change with the enactment of the AMA. The court declined to consider the fair process doctrine because Mr. Frantzis did not raise the argument himself.The United States Court of Appeals for the Federal Circuit affirmed the Veterans Court's decision. The court agreed with the Secretary of Veterans Affairs that the AMA eliminated the same judge requirement because it removed the language expressly requiring the same judge for the hearing and final determination. The court also disagreed with Mr. Frantzis' argument that 38 U.S.C. § 7102 supplies a same Board member requirement, stating that the unchanged language of § 7102 cannot be the basis for the same member requirement in the AMA system. The court concluded that the statutory scheme and its history are clear—the same judge is not required to both conduct the hearing and author the final determination under the AMA. View "FRANTZIS v. MCDONOUGH " on Justia Law

The case involves M&T Farms, a California general partnership between two farmers, who purchased crop insurance under the Whole-Farm Revenue Protection Pilot Policy (the “WFRP Policy”) from Producers Agriculture Insurance Company (“ProAg”), an insurer approved and reinsured by the Federal Crop Insurance Corporation (FCIC). M&T Farms and a third farmer sell farm commodities through a storefront, B&T Farms, which owns their business name and goodwill and is also a California general partnership. M&T Farms filed a claim seeking the full policy amount, which ProAg denied. The FCIC concluded that the WFRP Policy does not allow a partner who files taxes on a fractional share of farming activity conducted by a partnership to be eligible for WFRP coverage for the fractional share of that farming activity.The United States District Court for the Northern District of California granted summary judgment in favor of the FCIC. M&T Farms challenged the FCIC’s decision that a partnership “holding the business name and good will of [others] (i.e., marketing and selling the commodities produced)” is engaged in “farming activity” under section 3(a)(4) of the WFRP Policy, and that therefore, any entity reporting a fractional share of the partnership’s activity on its tax returns is ineligible for WFRP Policy coverage.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that the WFRP Policy contained an ambiguity regarding the definition of “farming activity.” The FCIC’s conclusion that a partnership selling its partners’ products and holding their goodwill and business name was engaged in “farming activity” under section 3(a)(4) of the policy had a reasonable basis and was also reasonable as a matter of policy. Because the FCIC’s interpretation of “farming activity” in the WFRP Policy was reasonable, it survived APA arbitrary and capricious review. The court also held that the term “farming activity” in the WFRP policy was genuinely ambiguous, the FCIC’s conclusion had a reasonable basis, and the FCIC’s conclusion was entitled to controlling weight. View "M & T FARMS V. FEDERAL CROP INSURANCE CORPORATION" on Justia Law

The case revolves around Green Rock LLC, a company that solicited taxpayers to invest in arrangements promising conservation-easement deductions. The Internal Revenue Service (IRS) issued Notice 2017-10, which required taxpayers and their advisors to comply with reporting requirements when claiming deductions for donations of conservation easements. Green Rock challenged this notice, arguing that the IRS violated the Administrative Procedure Act by issuing the notice without public notice and comment.Previously, the district court ruled in favor of Green Rock, stating that the IRS had unlawfully promulgated Notice 2017-10 because Congress did not expressly authorize its issuance without notice and comment. The district court set Notice 2017-10 aside for Green Rock.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that Notice 2017-10 was a legislative rule and Congress did not expressly exempt the IRS from notice-and-comment rulemaking. Therefore, Notice 2017-10 is not binding on Green Rock. The court clarified that its decision was specific to Notice 2017-10 and did not rule on the validity of any other listed transaction not before it. View "Green Rock LLC v. Internal Revenue Service" on Justia Law

Leachco, Inc., an Oklahoma corporation that manufactures and markets various products, appealed the denial of its request for a preliminary injunction to halt administrative enforcement proceedings by the Consumer Product Safety Commission (CPSC). Leachco argued that the statutory removal protections for CPSC commissioners and administrative law judges (ALJs) violated Article II of the Constitution and the separation of powers. The district court denied Leachco's motion for a preliminary injunction, stating that even if Leachco's constitutional arguments were valid, the alleged constitutional violations were insufficient to establish that Leachco would suffer "irreparable harm" if the injunction was denied.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that under current Supreme Court and Tenth Circuit precedent, Leachco's subjection to proceedings before an agency whose officials allegedly have unconstitutional protection against removal is insufficient, by itself, to establish irreparable harm. The court also found that Leachco failed to show that the removal protections for CPSC commissioners and its administrative law judge were unconstitutional. Therefore, Leachco failed to satisfy the irreparable harm requirement necessary to obtain a preliminary injunction. View "Leachco v. Consumer Product Safety Commission" on Justia Law

Michelle Oksman sued the City of Idaho Falls after slipping and falling on a wet surface in the lobby of the West Deist Aquatic Center, a facility owned and operated by the City. Oksman alleged negligence on the part of the City. The district court initially granted the City's motion for summary judgment, concluding that the City had no actual notice of a dangerous condition and did not fail to take reasonable action to remedy potential hazards. However, the court later withdrew its grant of summary judgment after Oksman identified the person who had allegedly stated that people frequently fell in the area where she had fallen. The case proceeded to a jury trial, during which the district court limited Oksman's testimony and declined to give a jury instruction Oksman requested regarding the reasonable value of necessary services. The jury returned a verdict in favor of the City, and the district court dismissed Oksman's complaint with prejudice. Oksman appealed.The Supreme Court of the State of Idaho vacated the district court's judgment and remanded the case for a new trial. The Supreme Court found that the district court had erred in limiting Oksman's testimony about a statement made by the manager of the aquatic center, which was crucial to Oksman's case. The Supreme Court also provided guidance on issues likely to arise again on remand, including the use of depositions for impeachment and the use of leading questions. The Supreme Court further vacated the district court's award of costs to the City as the prevailing party. Neither party was awarded attorney fees on appeal. View "Oksman v. City of Idaho Falls" on Justia Law