Justia Government & Administrative Law Opinion Summaries

The case involves a group of disabled students who sued the Superintendent of Public Instruction and the Office of the Superintendent of Public Instruction in Washington State. The students claimed that the state's practice of discontinuing special education services at the end of the school year in which a student turns 21 violated the Individuals with Disabilities Education Act (IDEA). The IDEA generally requires states to provide special education to disabled students until their 22nd birthday, but allows states to discontinue services as early as age 18 if providing special education to older students would be inconsistent with state law or practice. The students argued that because Washington offers certain adult-education programs to 21-year-olds, it should also be required to provide special education to disabled 21-year-olds.The United States District Court for the Western District of Washington denied the students' motion for a preliminary injunction, holding that the students had not shown that they would suffer irreparable harm if the injunction was not granted. The court also concluded that the students were not likely to succeed on the merits of their claim because the adult-education programs in Washington charged a tuition fee, and therefore did not constitute "free public education."The United States Court of Appeals for the Ninth Circuit vacated the district court's order and remanded the case for further proceedings. The appellate court held that the students had a high likelihood of success on the merits of their claim because the availability of the adult-education programs in Washington triggered an obligation under the IDEA to provide special education to disabled 21-year-olds. The court also found that the students would suffer irreparable harm from the denial of access to special education. The court concluded that the balance of hardships tipped in the students' favor and that an injunction would be in the public interest. View "N. D. V. REYKDAL" on Justia Law

The case involves Jacobo Jajati, a U.S. citizen, who had his membership in the Secure Electronic Network for Travelers Rapid Inspection (SENTRI) program revoked by the U.S. Customs and Border Protection (CBP). SENTRI is a program that allows pre-approved, low-risk travelers to cross the U.S.-Mexico border more easily. Jajati's membership was revoked, reinstated, and then revoked again without explanation. Jajati filed a lawsuit claiming that CBP's decision to revoke his SENTRI membership was arbitrary and capricious, in violation of the Administrative Procedure Act (APA).The district court dismissed Jajati's claim, ruling that CBP's decisions to revoke SENTRI memberships were not subject to judicial review because the administration of SENTRI was committed to agency discretion under the APA. The court held that there were no judicially manageable standards to assess how and when CBP should exercise its discretion to revoke SENTRI memberships.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that the APA does not bar judicial review of Jajati's claims. The court found that while CBP has broad discretion to revoke SENTRI memberships, the APA recognizes that discretion can be abused. The court concluded that the law governing SENTRI provides meaningful standards under which courts can review whether CBP wielded its discretion in a permissible manner. The case was remanded to the district court to consider whether CBP's decision to revoke Jajati's SENTRI membership violated the APA. View "JAJATI V. UNITED STATES CUSTOMS AND BORDER PROTECTION" on Justia Law

An inmate, Timothy Finley, who suffers from severe psychiatric disorders, was placed in a heavily restrictive cell in administrative segregation for approximately three months by prison officials. Finley brought a case against the deputy wardens, Erica Huss and Sarah Schroeder, alleging violations of the Eighth Amendment and his right to procedural due process, as well as disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.The district court granted summary judgment to Huss and Schroeder on all claims. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision on Finley’s procedural due process and statutory discrimination claims. However, the court reversed the lower court's decision on Finley’s Eighth Amendment claim, finding that he presented sufficient evidence to find that the deputy wardens violated his clearly established rights. The court remanded the case for further proceedings on the Eighth Amendment claim. View "Finley v. Huss" on Justia Law

The case revolves around the Employees Retirement System of the Government of the Commonwealth of Puerto Rico (ERS), which was established in 1951 as the Commonwealth's pension program for public employees. The appellants are seven individual beneficiaries of pensions paid by ERS. They had been litigating claims against UBS Financial Services Inc. (UBS) in the Commonwealth Court of First Instance related to UBS's role in issuing ERS pension funding bonds in 2008. Meanwhile, in January 2022, as part of its broad authority to promulgate orders necessary to carry out the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), the district court confirmed the Modified Eighth Amended Title III Joint Plan of Adjustment (the Plan).The district court had previously confirmed the Plan, which implemented several changes related to ERS and its pension plan payments to retired Commonwealth employees. The Plan replaced the Committee with the Avoidance Action Trustee as the plaintiff with exclusive power to prosecute the Underwriter Action and recover damages that ERS incurred. The Plan also ordered the immediate dissolution of ERS.UBS filed a motion to enforce the Plan, requesting that the district court enjoin the ERS Beneficiaries from pursuing the Commonwealth Action. The district court granted UBS's motion and enjoined the ERS Beneficiaries from pursuing the Commonwealth Action. The district court concluded that the ERS Beneficiaries' Commonwealth Action claims were rooted in a generalized injury and were derivative of ERS's right to recover on its own behalf. The district court further rejected the ERS Beneficiaries' arguments that they were entitled to recover for non-derivative general tort claims against UBS under various Commonwealth statutes.The United States Court of Appeals for the First Circuit affirmed the district court's decision, concluding that the ERS Beneficiaries sought to raise derivative claims that belong exclusively to the Trustee or the Commonwealth. The court held that continued litigation of the FAC's derivative claims violates the terms of the Plan and PROMESA. View "UBS Financial Services Inc. v. Estate of Jose Nazario Serrano" on Justia Law

The case involves the West Virginia Department of Health, Office of the Chief Medical Examiner, and Dr. Allen R. Mock (collectively "Petitioners") and Dr. Patsy Cipoletti, Jr., administrator of the estate of his deceased wife, June Cipoletti ("Respondent"). The Respondent filed a complaint against the Petitioners, alleging that they violated the West Virginia Medical Professional Liability Act (MPLA) by negligently determining Mrs. Cipoletti’s cause of death. The Petitioners filed a motion to dismiss, arguing that the Respondent had not asserted a proper cause of action under the MPLA. The circuit court denied the motion to dismiss, determining that the MPLA applied and that Petitioners were not entitled to qualified immunity.The Circuit Court of Kanawha County denied the Petitioners' motion to dismiss. The court determined that the MPLA applied and that Petitioners were not entitled to qualified immunity. The court found that Dr. Mock’s conduct fell under and was governed by the MPLA, thus depriving Petitioners of qualified immunity.The Supreme Court of Appeals of West Virginia reversed the circuit court's decision. The court found that the Petitioners' actions were discretionary and not in violation of any "clearly established statutory or constitutional rights or laws" and were not "otherwise fraudulent, malicious, or oppressive." Therefore, the court concluded that the Petitioners were entitled to qualified immunity from the lawsuit. The court also found that the Respondent had failed to plead a viable MPLA cause of action against the Petitioners. The court remanded the case to the circuit court with directions to grant the Petitioners' motion to dismiss. View "West Virginia Department of Health v. Cipoletti" on Justia Law

In September 2021, John Sandy Campbell filed a lawsuit against her former employer, the Los Angeles Unified School District, alleging racial discrimination and retaliation for whistleblowing. These allegations were in violation of Labor Code sections 1102.5 and 1106 and Government Code section 12940 (the Fair Employment and Housing Act). The District demurred, arguing that Campbell had not complied with the Government Code’s claim presentation requirement and that the statute of limitations barred her cause of action under the Act. The trial court sustained the District's demurrer without leave to amend, citing Le Mere v. Los Angeles Unified School District and Government Code section 12965, subdivision (c)(1)(C).The Court of Appeal of the State of California Second Appellate District Division Eight reviewed the trial court's ruling independently and applied the standard for demurrers. The court agreed with the trial court, stating that a plaintiff suing a public entity for damages must timely present a written claim to the entity before filing suit. Campbell had not demonstrated that she substantially complied with the claim presentation requirement. Furthermore, Campbell's amended complaint did not plead compliance with the claim presentation requirement.Additionally, Campbell's claim for violation of the Act was time-barred. The Department of Fair Employment and Housing had provided Campbell a Right to Sue notice dated October 9, 2018, giving her one year to file a civil action. Campbell did not sue until September 2021, making her suit untimely. The court also rejected Campbell's argument that the discovery rule saved her lawsuit. The court affirmed the judgment and order sustaining the demurrer without leave to amend and awarded costs to the respondent. View "Campbell v. L.A. Unified School Dist." on Justia Law

The case involves the United States government's appeal against a district court's order to pay monetary sanctions for failing to disclose information that suggested its key witness in a criminal trial was willing to shape her testimony in exchange for certain benefits. The case arose from a five-body homicide trial where the government's star witness, Esmeralda, was willing to alter her testimony for benefits. The defense learned about this not from the government, but from Esmeralda's counsel. The district court found that the government's failure to disclose this information violated the defendant's due process rights under Brady v. Maryland, and imposed sanctions on the government.The district court's order was appealed by the government before the final judgment was issued in the underlying criminal case. The Ninth Circuit Court of Appeals affirmed the district court's order, holding that it had appellate jurisdiction under 28 U.S.C. § 1291 because the sanctions order satisfied the elements of the collateral-order doctrine.On the merits, the court found that the government had suppressed evidence, and that suppression was material under Brady. The court held that the district court's decision to exclude the testimony and impose sanctions was not an abuse of discretion. The court also held that the district court did not violate the government's sovereign immunity by imposing monetary sanctions under an exercise of its supervisory powers. View "USA V. CLOUD" on Justia Law

A group of environmental organizations challenged the U.S. Forest Service's approval of the Long Valley Exploration Drilling Project, a mineral exploration project on land in the Inyo National Forest in California. The Forest Service had approved the project by invoking two Categorical Exclusions (CEs) under the National Environmental Policy Act (NEPA), which allow certain actions to bypass more extensive environmental review. The environmental groups argued that the Forest Service could not combine two CEs to approve the project when neither CE alone could cover the entire project.The district court granted summary judgment in favor of the Forest Service and KORE Mining Ltd., the company that proposed the project. The environmental groups appealed to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit reversed the district court's decision. The court found that the two-phase project was a single proposed action and that the Forest Service's regulations prohibited combining CEs when no single CE could cover a proposed action alone. The court also held that the Forest Service's error in combining the two CEs was not harmless and remanded the case to the district court to enter summary judgment in favor of the environmental groups, vacating the agency's decision. View "FRIENDS OF THE INYO V. USFS" on Justia Law

The case involves Novartis Pharmaceuticals Corporation and United Therapeutics Corporation, both drug manufacturers, and the Health Resources and Service Administration (HRSA). The dispute centers around Section 340B of the Public Health Service Act, which mandates drug manufacturers to sell certain drugs at discounted prices to select healthcare providers. These providers often contract with outside pharmacies for distribution. The manufacturers argued that these partnerships have left the Section 340B program vulnerable to abuse, leading them to impose their own contractual terms on providers, such as limits on the number of pharmacies to which they will make shipments. The government contended that these restrictions violate the statute.The case was initially heard in the United States District Court for the District of Columbia. The district court ruled that Section 340B does not prohibit manufacturers from limiting the distribution of discounted drugs by contract.The case was then reviewed by the United States Court of Appeals for the District of Columbia Circuit. The court agreed with the district court's ruling, stating that Section 340B does not categorically prohibit manufacturers from imposing conditions on the distribution of covered drugs to covered entities. The court further held that the conditions at issue in this case do not violate Section 340B on their face. The court did not rule out the possibility that other, more onerous conditions might violate the statute or that these conditions may violate Section 340B as applied in particular circumstances. The court affirmed the district court's decision to set aside the enforcement letters under review, while reserving the possibility of future enforcement under theories of liability narrower than the one pressed here. View "Novartis Pharmaceuticals Corporation v. Johnson" on Justia Law

The case revolves around a parolee, Eugene L. Lively, who was searched by parole officers during a home visit in February 2021. The officers were looking for a parole absconder they believed might be at Lively's residence. During the search, an officer found a small case used for headphones in Lively's pocket, which contained heroin. Lively was subsequently charged with one count of criminal possession of a controlled substance in the third degree.Lively moved to suppress the physical evidence obtained from him. The suppression court denied his motion, ruling that the search was lawful as the parole officers were performing their duties. Lively was convicted of third-degree criminal possession of a controlled substance after a bench trial. On appeal, the Appellate Division affirmed the judgment in a split decision. The majority held that the search was substantially related to the parole officers' duties. Two dissenting justices argued that the search was unlawful as there was no evidence that it was related to Lively's status as a parolee or that he had violated his parole conditions.The Court of Appeals reversed the lower courts' decisions. The court held that the People failed to establish at the suppression hearing that the search of Lively's pocket was substantially related to the parole officers' duties. The court found that the People did not provide evidence that Lively was aware of the absconder's parole status, that he was harboring an absconder, or that he was violating his parole conditions. The court concluded that the search of Lively's pocket was not substantially related to the parole officers' duties under the circumstances, and thus, the evidence obtained should have been suppressed. The court ordered the reversal of the Appellate Division's order and the dismissal of the indictment. View "People v Lively" on Justia Law