Justia Government & Administrative Law Opinion Summaries

The case revolves around a group of Texans who were receiving Pandemic Unemployment Assistance (PUA) until the Texas governor informed the Department of Labor that Texas would withdraw from its agreement with the Secretary of Labor to participate in the PUA program. The plaintiffs argued that the Federal Government violated the mandate in PUA that the Secretary of Labor “shall provide . . . assistance” to “any covered individual.”The United States District Court for the Western District of Texas dismissed the case, agreeing with the magistrate judge's recommendation. The judge reasoned that the CARES Act, which established the PUA, required the existence of an agreement with a state for the payment of benefits. The judge also noted that the Act did not provide a mechanism for the Secretary to pay out benefits in the absence of an agreement with the relevant state. The judge concluded that Congress intended for the funds to be administered solely by the states.The plaintiffs appealed to the United States Court of Appeals for the Federal Circuit. The court affirmed the lower court's decision, stating that the PUA does not require the Secretary to pay PUA benefits to individual citizens; rather, the Secretary must provide assistance through agreements with the states. The court concluded that the plaintiffs failed to state a claim under the Little Tucker Act. View "CREAGER IRELAND v. US " on Justia Law

The case involves Daniel D. Barry, a veteran who appealed a decision by the United States Court of Appeals for Veterans Claims. Barry had argued that the Board of Veterans’ Appeals should have considered his entitlement to multiple special monthly compensation (SMC) increases, rather than just one, under 38 C.F.R. § 3.350(f)(3). The Veterans Court disagreed, interpreting § 3.350(f)(3) to permit only one SMC increase, regardless of how many qualifying disabilities Barry could demonstrate.The Veterans Court had previously remanded the case for further explanation and consideration of potential additional SMC entitlement. The Board then concluded that Barry could not show entitlement to an additional SMC increase under 38 C.F.R. § 3.350(f)(4). Barry appealed this decision to the Veterans Court, arguing that the Board erred by not considering whether he would be entitled to an additional SMC increase under 38 C.F.R. § 3.350(f)(3).The United States Court of Appeals for the Federal Circuit reversed the decision of the Veterans Court. The court held that § 3.350(f)(3) does not limit how many SMC increases can be provided; instead, it is a mandatory entitlement that can apply multiple times, subject to a statutory cap. The court remanded the case for further proceedings, including the calculation of the number of intermediate-rate SMC increases Barry should receive. View "BARRY v. MCDONOUGH " on Justia Law

The case involves a dispute over a proposed project to significantly alter the California State Capitol complex. The plaintiff, Save the Capitol, Save the Trees (Save the Capitol), appealed against an order discharging a peremptory writ of mandate issued by the trial court. The writ was issued following a previous court decision that found an environmental impact report (EIR) for the project, prepared by the defendant Department of General Services and the Joint Committee on Rules of the California State Senate and Assembly (collectively DGS), failed to comply with the California Environmental Quality Act (CEQA). The writ directed DGS to vacate in part its certification of the EIR and all associated project approvals, and to file a final return to the writ “upon certification of a revised EIR.”The trial court had previously denied two petitions for writ of mandate, one sought by Save the Capitol and the other by an organization named Save Our Capitol!. The Court of Appeal reversed in part and affirmed in part the trial court’s denial. On remand, the trial court issued a peremptory writ of mandate directing DGS to vacate in part its certification of the EIR and all associated project approvals. After DGS partially vacated its certification of the EIR and all associated project approvals, it revised, recirculated, and certified the revised final EIR. DGS then partially reapproved the project without one of the project components, the visitor center. DGS thereafter filed its final return and the trial court discharged the writ, over plaintiff’s objection, without determining whether the revised final EIR remedied the CEQA violations the Court of Appeal had identified in its opinion.In the Court of Appeal of the State of California Third Appellate District, Save the Capitol argued that the discharge of the writ was premature because the writ not only required DGS to revise and recirculate the defective portions of the EIR, but also to certify a revised EIR consistent with the previous court decision before the writ could be discharged. The court agreed with Save the Capitol, concluding that the trial court must determine that the revised EIR is consistent with the previous court decision before discharging the writ. The court reversed the judgment and remanded the case for further proceedings. View "Save the Capitol, Save the Trees v. Dept. of General Services" on Justia Law

The case involves an appeal by Wheatland Tube Company against a decision by the U.S. Court of International Trade, which affirmed the U.S. Department of Commerce’s remand determination concerning the scope of an antidumping duty order on certain steel pipes imported from Thailand. The dispute centers on whether certain imports of steel pipes, specifically those that are "dual-stenciled" as both standard pipes and line pipes, fall within the scope of the existing antidumping duty order.The U.S. Court of International Trade initially found that the Department of Commerce unlawfully expanded the scope of the antidumping duty order by determining that it covered dual-stenciled pipes. On remand, the Department of Commerce, under protest, concluded that the antidumping duty order did not cover dual-stenciled pipes. The U.S. Court of International Trade sustained this determination.On appeal, the United States Court of Appeals for the Federal Circuit reversed the decision of the U.S. Court of International Trade. The Court of Appeals held that the Department of Commerce’s initial determination that dual-stenciled pipes fall within the scope of the antidumping duty order was reasonable and supported by substantial evidence. The Court of Appeals found that the lower court's interpretation lacked support in the record and failed to give sufficient deference to the Department of Commerce under the substantial evidence standard of review. View "SAHA THAI STEEL PIPE PUBLIC COMPANY LIMITED v. US " on Justia Law

Chamma K. Brandon, an inmate in the custody of the New York State Department of Corrections and Community Supervision, filed a lawsuit against three prison officials. Brandon alleged that the officials violated his First Amendment right to the free exercise of religion by denying him a special meal in celebration of Eid al-Adha. He also claimed that one of the officials, Mark Royce, violated his Eighth Amendment right to be free from cruel and unusual punishment by ordering that his housing block be constantly illuminated.The United States District Court for the Southern District of New York granted the defendants' motion for summary judgment on Brandon's First Amendment claim and denied Brandon's request to reopen discovery for a second time to permit expert testimony on his Eighth Amendment claim. Following a trial, a jury found that Royce had not violated Brandon's Eighth Amendment right.On appeal, the United States Court of Appeals for the Second Circuit agreed with Brandon that the district court erred in granting summary judgment to the defendants on his First Amendment claim. The court found that there was a genuine dispute of material fact regarding whether Brandon had an alternative means of exercising his right to the free exercise of religion. The court also found that the penological concerns raised by the defendants did not support granting judgment as a matter of law in their favor. However, the court found no error in the district court's denial of Brandon's motion to reopen discovery. The court therefore vacated in part and affirmed in part the district court's decision. View "Brandon v. Royce" on Justia Law

The case involves a class action lawsuit filed by plaintiff Harold Malmquist against the City of Folsom (City). The plaintiff alleged that the City failed to maintain proper corrosion control measures at its water treatment plant, causing the pH level of its water to rise and become corrosive. This, in turn, led to pinhole leaks in copper pipes receiving the water, damaging persons and property. The plaintiff sought class certification, defining the class as all individuals and entities who have owned or leased real property in the City, plumbed with copper piping receiving water from the City’s plant since February 23, 2015.The trial court denied the plaintiff's motion for class certification. The court found that the plaintiff had not shown that common issues predominated over individual ones. The court reasoned that the existence, cause, and extent of damage to copper piping required individual proof. The court also overruled the plaintiff's objections to the City's expert witness, concluding that the expert was qualified and his opinion was founded on reliable information.On appeal, the Court of Appeal of the State of California Third Appellate District affirmed the trial court's decision. The appellate court found that the trial court did not abuse its discretion in denying class certification. The court agreed with the trial court's conclusion that individual issues predominated over common ones. The court also found no error in the trial court's decision to overrule the plaintiff's objections to the City's expert witness. The court concluded that the expert was qualified and his opinion was founded on reliable information. View "Malmquist v. City of Folsom" on Justia Law

The case involves D.K., a patient diagnosed with an unspecified schizophrenia spectrum and other psychotic disorders, who was found incompetent to stand trial and committed to the Department of State Hospitals (DSH) by the Orange County Superior Court. After D.K.'s transfer to Napa State Hospital, DSH filed a petition for an interim order to compel involuntary medication of D.K. with antipsychotic medication. An administrative law judge (ALJ) conducted an evidentiary hearing and ordered D.K. involuntarily medicated from January 17, 2023, to February 7, 2023. D.K. filed a petition for a writ of administrative mandate with the Napa County Superior Court, challenging the medication order. The superior court denied her petition, concluding D.K. was not entitled to writ review.The Court of Appeal of the State of California First Appellate District Division Three found that D.K.'s appeal was moot because the order had expired and no meaningful relief could be effectuated through review of that order. However, the court exercised its discretion to address D.K.'s appeal of the superior court's finding that the statutory scheme of section 1370 precluded her from filing a writ of administrative mandamus to challenge the medication order. The court concluded that both the significant liberty interests at issue and the language of section 1370 support D.K.'s right to seek writ review. The court reversed the superior court's holding that D.K. was not entitled to writ review. However, it dismissed as moot D.K.'s challenge to the court's finding that substantial evidence supported the involuntary medication order, so it did not remand the case for further proceedings. View "D.K. v. Office of Admin. Hearings" on Justia Law

The plaintiff, Brady Helm, tripped and fell on a wire cable while walking to a recreational area at Diaz Lake. The wire cable was suspended between two wooden poles and was intended to prevent vehicles from accessing a pedestrian pathway. Helm sued the County of Inyo and the City of Los Angeles, alleging causes of action for dangerous condition on public property, premises liability, and negligence.The defendants prevailed on summary judgment in the Superior Court of Inyo County, arguing that Helm tripped while walking along a trail, and thus, they were immune under Government Code section 831.4 (trail immunity). Helm appealed the final judgment, contending that trail immunity does not apply in this case and that disputed questions of material facts exist regarding the alleged dangerous condition of the subject public property.The Court of Appeal, Fourth Appellate District Division One State of California, disagreed with Helm’s first contention and concluded that the trial court did not err in granting the defendants' motion for summary judgment because trail immunity barred Helm’s claims. The court found that the area where Helm fell was a trail for purposes of section 831.4 and the wooden poles and wire cable were incorporated into the design of the trail. Therefore, the court affirmed the judgment. View "Helm v. City of Los Angeles" on Justia Law

The case involves the Jibril family, who alleged that they were wrongfully placed on the U.S. Government’s terrorist watchlist, known as the "Selectee List." The family claimed that this placement resulted in extensive and intrusive security screenings and significant delays during their domestic and international travels. They filed a lawsuit against the Secretary of the Department of Homeland Security and other federal officials, alleging violations of the Fourth and Fifth Amendments and the Administrative Procedure Act.The District Court initially dismissed the case for lack of standing, as the Government neither confirmed nor denied the Jibrils’ Selectee List status. The Court of Appeals reversed this decision in part, holding that the Jibrils had plausibly alleged that they were on a terrorist watchlist and faced imminent risk of undue Government actions sufficient to support most of their claims for prospective relief.On remand, the Government filed a renewed motion to dismiss, this time submitting an ex parte declaration to the District Court for in camera review. Based on this submission, the District Court again dismissed the case, holding that the Jibrils lacked standing to pursue their complaint for prospective relief.The Court of Appeals affirmed the District Court's decision, agreeing that the Jibrils lacked standing to seek forward-looking relief. The court also held that the District Court did not abuse its discretion in relying on the Government’s ex parte submission to address matters implicating national security concerns. Finally, the court found no error in the District Court’s denial of the Jibrils’ motion for leave to amend their complaint. View "Jibril v. Mayorkas" on Justia Law

This case involves a dispute over the Environmental Protection Agency's (EPA) implementation of the Clean Air Act’s Renewable Fuel Standards Program. The program requires the petroleum industry to introduce increasing volumes of renewable fuel into the nation's transportation fuel supply each year. However, Congress overestimated the speed at which domestic production of renewable fuel could expand, leading the EPA to reduce the statutorily required renewable fuel requirements annually.The case was brought before the United States Court of Appeals for the District of Columbia Circuit by two sets of petitioners. The first set, the Biofuel Petitioners, produce cellulosic biofuels and argue that the EPA's standards are set too low. The second set, the Refiner Petitioners, are fossil fuel refiners and retailers subject to the volume requirements and contend that the standards are too high.The court held that the EPA complied with the law and reasonably exercised its discretion in setting the renewable fuel requirements for the years 2020, 2021, and 2022. The court therefore denied the petitions for review. The court found that the EPA had the statutory authority to impose a supplemental volume for 2022 to make up for volume that should have been satisfied in 2016. The court also concluded that the EPA's new formula for calculating the annual percentage standards was not arbitrary or capricious. View "Sinclair Wyoming Refining Company LLC v. EPA" on Justia Law