Justia Government & Administrative Law Opinion Summaries

The case involves Daniel Lamont Mathis, who was convicted of multiple offenses, including Hobbs Act robbery, racketeering, and violent crimes in aid of racketeering activity, all in connection with the carjacking, kidnapping, and execution-style murder of a Virginia police officer. Initially, Mathis was sentenced to four concurrent life sentences and a consecutively imposed term of 132 years’ imprisonment. However, after an appeal and the passage of the First Step Act of 2018, which amended the sentencing structure for second or subsequent convictions under 18 U.S.C. § 924(c), the district court resentenced Mathis to four concurrent life sentences, plus 48 years’ imprisonment.The district court also set forth mandatory and discretionary conditions of supervised release. One of the discretionary conditions was that Mathis would be subject to warrantless search and seizure to ensure compliance with these conditions. However, the written judgment included additional language, stating that Mathis must warn any other occupants that the premises may be subject to searches pursuant to this condition.Mathis appealed, arguing that the additional language in the written judgment constituted error under United States v. Rogers and United States v. Singletary. The United States Court of Appeals for the Fourth Circuit agreed with Mathis, finding that the requirement to warn other occupants was inconsistent with the orally pronounced condition. The court held that this discrepancy constituted reversible error under Rogers and Singletary. As a result, the court vacated Mathis' sentence and remanded the case for a full resentencing. View "US v. Mathis" on Justia Law

James and Levi Garrett, a father and son farming duo in South Dakota, were found guilty by a jury of making false statements in connection with federal crop insurance. The Garretts had participated in a federal crop insurance program, administrated by Crop Risk Services (CRS) and backed by the Risk Management Agency of the United States Department of Agriculture (USDA). They had obtained insurance for sunflower crops in 2018, and James had obtained insurance for a corn crop in 2019. The Garretts were accused of falsely certifying the number of acres of sunflowers and corn they planted in 2018 and 2019 respectively, and subsequently reporting harvest losses to CRS.The case went to trial in October 2022. The jury heard from several witnesses and examined dozens of exhibits. At the conclusion of the trial, James was convicted on two counts of making a false statement in connection with insurance for sunflower and corn crops, and Levi was convicted on one count of making a false statement in connection with insurance for a sunflower crop. The Garretts moved for judgment of acquittal, and in the alternative, a new trial, arguing there was insufficient evidence to support their convictions. The district court denied their motion.The Garretts appealed to the United States Court of Appeals for the Eighth Circuit, challenging the district court’s evidentiary rulings and its denial of their post-trial motions. They argued that the district court erred in admitting certain evidence and excluding others, and that there was insufficient evidence to support their convictions. The Court of Appeals affirmed the judgment of the district court, concluding that the trial record supported the jury verdict and that the district court did not err in its evidentiary rulings or in denying the Garretts' post-trial motions. View "United States v. Garrett" on Justia Law

Sarah Watkins filed a lawsuit against the City of St. Louis, Missouri, and six individual police officers under 42 U.S.C. § 1983, alleging that the officers used excessive force during a routine traffic stop. Watkins was stopped for a traffic violation near St. Louis Lambert International Airport. After she was asked to step out of her car, she was handcuffed and allegedly subjected to verbal abuse, forced into a vehicle, pepper-sprayed, and repeatedly hit on the leg with a baton. Watkins was later treated for injuries to her legs, face, and body.The district court dismissed Watkins's claims, ruling that the officers were entitled to qualified immunity on her Fourth Amendment excessive force claims. The court also dismissed the claims against the City, stating that Watkins failed to provide sufficient facts to state a claim for municipal liability under § 1983 and Monell v. Department of Social Services.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal of Watkins's claims. The court found that Watkins had sufficiently alleged a violation of her Fourth Amendment right to be free from unreasonable seizures. The court also determined that this right was clearly established at the time of the traffic stop. Therefore, the court reversed the district court's dismissal of Watkins's Fourth Amendment excessive force claims against the individual officers. However, the court affirmed the dismissal of Watkins's § 1983 claims against the City, as she had not alleged sufficient facts to support the existence of an unconstitutional policy or custom. View "Watkins v. City of St. Louis, Missouri" on Justia Law

The case involves a mother, J.C. (Jan), who was diagnosed with bipolar disorder with psychotic features. The New Jersey Division of Child Protection and Permanency (the Division) became involved with Jan and her family in 2018 when she was involuntarily hospitalized for manic and paranoid behavior. The Division implemented a safety plan that mandated temporary supervision of Jan’s contact with her children. After a series of referrals and investigations, the Division filed a complaint in 2020, and the Family Part granted the Division care and supervision of the children. In 2021, the Law Guardian sought to dismiss the Title 30 action due to Jan’s lack of cooperation with the Division. The court discontinued the Division’s care and supervision of the children but dismissed the litigation with restraints, considering Jan's mental health issues.The Appellate Division affirmed the lower court's decision, and the Supreme Court of New Jersey granted certification. The Appellate Division held that the family court could dismiss a Title 30 action while maintaining restraints on a parent’s conduct. The court reasoned that the family court did not enter permanent restraints but continued the restraints that existed during the litigation.The Supreme Court of New Jersey reversed the Appellate Division's decision. The court held that the family court does not have the authority under N.J.S.A. 30:4C-12 to dismiss a Title 30 action and continue restraints on a parent’s conduct. If the family court finds that it is in the best interests of the child to continue the restraints on a parent’s conduct, it must keep the case open to facilitate judicial oversight of the Division’s continued involvement, while safeguarding a parent’s right to counsel. The case was remanded to the Family Part to reinstate the Title 30 action or dismiss the case without restraints. View "New Jersey Division of Child Protection and Permanency v. J.C. and K.C." on Justia Law

The case involves John R. Tibbetts, a teacher, and his employer, the Worth County School District. The District offered Tibbetts a contract for the upcoming school year, but Tibbetts did not return the signed contract within the stipulated time. The District then informed Tibbetts that his employment would end when his current contract expired. Tibbetts sued the District for breach of contract, arguing that the offered contract did not comply with Georgia's statutory requirements for teacher contracts because it was missing terms and contained blanks. Therefore, he contended, his employment contract for the prior school year was renewed by operation of law.The trial court granted the District's motion for summary judgment, holding that there was no existing written contract between the parties that operated to waive sovereign immunity under the ex contractu clause of the Constitution of the State of Georgia. The trial court found that the District offered Tibbetts a contract that complied with the statutory requirements, but that Tibbetts did not timely accept that offer.The Court of Appeals reversed the trial court's decision. It determined that the contract the District offered Tibbetts for the upcoming school year failed to comply with the requirements of the statute; therefore, Tibbetts’s contract for the previous school year was renewed by operation of law and constituted a contract in writing. The Court of Appeals reasoned that Tibbetts’s claim was one for breach of a written contract, and sovereign immunity was waived pursuant to the ex contractu clause.The Supreme Court of Georgia reversed the Court of Appeals' decision. It held that the Court of Appeals erred in reversing the grant of summary judgment in favor of the District because the employment contract the District offered Tibbetts for the upcoming school year satisfied the requirements of the statute. Because Tibbetts failed to timely accept this offer, no written contract exists to support Tibbetts’s claim for breach of a written contract. Absent such a claim, there is no waiver of sovereign immunity pursuant to the ex contractu clause. View "WORTH COUNTY SCHOOL DISTRICT v. TIBBETTS" on Justia Law

Darion Benjamin Woods pleaded guilty to damaging the property of a foreign official in the United States. Woods and his co-defendant broke into the British Consul General’s family home in Houston, Texas, stealing various items and causing over $50,000 in damages. Woods was arrested and charged with one count of damaging property occupied by a foreign official. He pleaded guilty without a plea agreement. The presentence investigation report calculated Woods’s Guidelines imprisonment range at 12 to 18 months. Woods objected to the report, seeking a two-level reduction for acceptance of responsibility.The district court awarded Woods’s requested two-point reduction for acceptance of responsibility and calculated the Guidelines range at 8–14 months. However, the court varied upwards and sentenced Woods to 30 months in prison. The court concluded that this sentence was necessary to satisfy the 3553(a) factors and to protect the community given Woods’s prior criminal history. The court also ordered Woods to pay $56,636.15 in restitution and imposed a 3-year term of supervised release. Woods timely appealed, arguing that his above-Guidelines sentence is substantively unreasonable and that the condition in the written judgment that he must “refrain from the excessive use of alcohol” conflicts with the oral pronouncement that “while in the program, he’s not to consume alcohol excessively.”The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the district court did not abuse its discretion in sentencing Woods to 30 months in prison, which was above the Guidelines range. The court also found that the written condition of supervised release that Woods must "refrain from the excessive use of alcohol" conflicted with the oral pronouncement that "while in the program, he’s not to consume alcohol excessively." The court modified the sentence to reflect that while Woods is in the drug-treatment program, he’s not to consume alcohol excessively. View "United States v. Woods" on Justia Law

The case revolves around a child, R.N., who was removed from his mother's care and placed in foster care with Ben and Charissa Wagner. The Wagners had previously adopted two of the mother's other children. The Department of Public Health and Human Services was granted temporary legal custody of R.N. and ordered the mother to complete a treatment plan. The Department later filed a petition to terminate the mother's parental rights due to her failure to complete the treatment plan and alleged abandonment of R.N. However, the mother began to engage with the Department and made positive changes, leading to the Department's shift from termination to reunification.The Wagners, unhappy with the Department's change of stance, filed a motion to intervene, asserting that it was appropriate under M. R. Civ. P. 24 and § 41-3-422(9)(b), MCA. The District Court granted the Wagners' intervention motion, despite objections from the mother, the Department, and the guardian ad litem. The Wagners then filed a motion seeking an order for R.N. to be immediately placed in their care and for the Department to pursue termination of the mother's parental rights. The District Court did not set a hearing or issue a determination on the Wagners' motion. The Department filed a motion to dismiss the case, which the District Court granted.The Supreme Court of the State of Montana affirmed the District Court's decision to dismiss the case. The Supreme Court found that the District Court had misinterpreted the law when it allowed the Wagners to intervene. The court also ruled that the Wagners did not have a fundamental liberty interest in the care and custody of R.N. because the mother's rights had not been terminated. Furthermore, the court held that neither the District Court nor the Supreme Court had the authority to order or compel the Department to refile and prosecute its petition for termination. View "In re R.N." on Justia Law

The case revolves around a defendant, Tara Shawnee Pritchett, who was on probation for two misdemeanor offenses. In September 2021, a detective conducted a warrantless search of Pritchett's room, believing she was on searchable probation. The search resulted in the discovery of U.S. currency and what was believed to be fentanyl. Pritchett was subsequently charged with one felony count of possession for sale of a controlled substance. However, Pritchett moved to suppress the evidence obtained from the search, arguing that her probation had been automatically terminated by Assembly Bill No. 1950 (AB 1950), which limited the maximum term of probation for most misdemeanor offenses to one year.The trial court granted Pritchett's motion to suppress the evidence. It concluded that Pritchett's probation had automatically terminated when AB 1950 became effective on January 1, 2021, several months before the search. The court also ruled that the "good faith" exception to the exclusionary rule did not apply, leading to the dismissal of the charge against Pritchett.The People appealed the trial court's decision to the Court of Appeal of the State of California, First Appellate District. They argued that the trial court erred in concluding that Pritchett's probation had terminated automatically due to AB 1950. They also contended that the "good faith" exception to the exclusionary rule should apply because the detective had made objectively reasonable efforts to determine Pritchett's probation status.The appellate court agreed with the People's latter contention and reversed the trial court's decision. The court found that the detective had acted in objectively reasonable good faith by relying on court records to verify Pritchett's probation status prior to conducting the search. The court concluded that applying the exclusionary rule in this case would not serve its purpose of deterring unlawful police conduct. Therefore, the court directed the trial court to set aside the order granting Pritchett's motion to suppress and to enter a new order denying the motion. View "People v. Pritchett" on Justia Law

The case involves journalist Robert Schilling's attempt to obtain records related to the Committee on Oversight and Reform of the United States House of Representatives' use of outside consultants as part of a congressional investigation. Schilling sought these records under the common law right of access, alleging that the hearings were part of a series of public-private collaborations targeting political opponents of the climate policy agenda. He claimed that the requested records would show that the Committee used unpaid consulting services to prepare for the hearings, in violation of federal law and House rules.The district court dismissed Schilling's petition, ruling that the Constitution's Speech or Debate Clause barred the case. The court held that the Clause acts as an absolute jurisdictional bar to suits seeking compelled disclosure of materials related to legislative activity. Schilling appealed this decision.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal, but on different grounds. The appellate court did not address the question of whether the Speech or Debate Clause barred Schilling's claim. Instead, it dismissed the case on the grounds of sovereign immunity. The court found that the documents Schilling sought were not "public records," and thus, there was no duty imposed on Congress to grant Schilling's request. As a result, the Larson-Dugan exception to sovereign immunity did not apply, and Schilling's claim was barred by sovereign immunity. View "Schilling v. United States House of Representatives" on Justia Law

An investigative reporter, Jason Leopold, sought access to the written directives of the United States Capitol Police and audits and reports prepared by the Inspector General of the Capitol Police. He invoked the District Court’s mandamus jurisdiction under 28 U.S.C. § 1361, claiming a common law right to access public documents and a statutory right under 2 U.S.C. § 1909(c)(1). The District Court dismissed these claims, holding that sovereign immunity barred the suit.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the District Court’s dismissals for lack of jurisdiction, but for different reasons. The court found that Leopold failed to establish that the Capitol Police had a clear, indisputable, and ministerial duty to provide access to the records. The court also rejected Leopold's argument that the Inspector General of the Capitol Police breached his duty to publish all audits and reports that recommend corrective action under 5 U.S.C. § 404(e)(1)(C), as applied to the Inspector General of the Capitol Police under 2 U.S.C. § 1909(c)(1). The court concluded that even if this duty existed, the Inspector General was forbidden from publishing the audits and reports due to their designation as "security information" under 2 U.S.C. § 1979. The dismissal was affirmed without prejudice, allowing Leopold to refile his complaint with the requisite allegations to satisfy the mandamus standard if he so desires and if he plausibly believes that he can prove those allegations. View "Leopold v. Manger" on Justia Law