Justia Government & Administrative Law Opinion Summaries

T-Mobile sought a refund for statutory service fees paid to the Kentucky Commercial Mobile Radio Service Emergency Telecommunications Board, arguing that the fees did not apply to prepaid cellular customers based on a prior court decision. The Board denied the refund request, leading T-Mobile to file a lawsuit in Franklin Circuit Court. The trial court ruled against T-Mobile, stating that it did not meet the common law refund requirements as outlined in Inland Container Corporation v. Mason County, which necessitates that payments be involuntary or made under misrepresentation.The Court of Appeals affirmed the trial court's decision, agreeing that T-Mobile's payments were voluntary and not subject to refund. T-Mobile then sought discretionary review from the Supreme Court of Kentucky. The Supreme Court granted review, heard oral arguments, and examined the record.The Supreme Court of Kentucky affirmed the Court of Appeals' decision. The court held that T-Mobile was not entitled to a common law refund because the payments were voluntary and not made under misrepresentation. The court emphasized that the payments were not collectible by summary process or fine and imprisonment, and T-Mobile had the opportunity to challenge the fees in court before paying them. Additionally, the court found no evidence of actual misrepresentation by the Board. Therefore, T-Mobile's claim for a common law refund was denied. View "Powertel Memphis, Inc. v. Commercial Mobile Radio Service Emergency Telecommunications Board" on Justia Law

A City of Houston police officer, while responding to an armed robbery, collided with another motorist, Maria Christina Gomez. The officer, Bobby Joe Simmons, was driving in heavy rain with his emergency lights on but did not engage his siren. He did not exceed the speed limit and applied his brakes when the traffic light turned yellow, but his car slid into the intersection and collided with Gomez's vehicle. Gomez sued the City for negligence, seeking damages for her injuries.The trial court granted the City’s plea to the jurisdiction, citing the Texas Tort Claims Act’s emergency exception, which preserves immunity unless the officer acted with "conscious indifference or reckless disregard for the safety of others." The Court of Appeals for the Fourteenth District of Texas reversed this decision, finding a fact question regarding the officer's recklessness. The City then supplemented its plea with additional evidence and appealed again after the trial court denied the plea.The Supreme Court of Texas reviewed the case de novo and concluded that the evidence showed, at most, ordinary negligence rather than recklessness. The court held that Simmons’s actions, including adjusting his radio and not exceeding the speed limit, did not demonstrate a willful or wanton disregard for safety. Consequently, the court reversed the Court of Appeals' judgment and rendered judgment dismissing Gomez’s claim against the City for lack of jurisdiction, reaffirming the City’s immunity under the Texas Tort Claims Act’s emergency exception. View "City of Houston v. Gomez" on Justia Law

Michael Cannata served as a firefighter for the town of Mashpee for over a decade before leaving in 2004 as a "deferred retiree." During his employment, he was enrolled in the town's group health insurance plan, but his enrollment ended upon his departure. In 2021, after turning fifty-five and beginning to collect retirement benefits, Cannata sought to re-enroll in the town's health insurance plan as a retiree. The town denied his request, citing various reasons, including his lack of "time in-service" and the town's practice of denying coverage to retirees not enrolled in the plan at the time of retirement.Cannata filed an action in the Superior Court, seeking a judgment declaring that the town's denial of benefits violated G. L. c. 32B, § 9. The Superior Court judge granted the town's motion to dismiss for failure to state a claim, concluding that Cannata was required to apply for continued coverage and pay the full premium cost during his deferral period in order to later enroll in the town's group health insurance plan upon retirement. Cannata appealed the decision.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that G. L. c. 32B, § 9, neither requires nor prohibits a municipality from enrolling individuals like Cannata in its group health insurance plan upon retirement. The court concluded that the third paragraph of the statute, which the lower court relied on, did not govern Cannata's case. The court determined that municipalities may, but are not obligated to, allow such individuals to enroll in group health insurance upon retirement. The court affirmed the judgment of dismissal on the alternative ground that Cannata's complaint failed to plausibly allege entitlement to relief beyond a speculative level. The case was remanded with instructions to dismiss the complaint without prejudice, allowing Cannata an opportunity to amend his request for declaratory relief. View "Cannata v. Town of Mashpee" on Justia Law

Joanne Pearson, a Republican candidate for Madison County Election Commissioner in District Three, won the election against Walter Young, Jr., a Democratic candidate, by a vote of 5,772 to 3,917. Pearson had filed her application to qualify as a candidate in January 2024, and the Madison County Board of Supervisors approved her candidacy in February 2024. Five citizens, collectively referred to as Brown, appealed the Board’s decision, arguing that Pearson’s application was incomplete and that there was a conflict of interest with the Board’s attorney, Spence Flatgard.The Madison County Circuit Court reviewed the case and denied Brown’s motion to disqualify Flatgard, affirming the Board’s decision to approve Pearson’s candidacy. The court found that Pearson’s application, despite some incomplete areas, met the statutory requirements for the position. Brown then appealed both decisions to the Supreme Court of Mississippi.The Supreme Court of Mississippi reviewed the case and affirmed the lower court’s decisions. The court held that the Board did not act arbitrarily or capriciously in approving Pearson’s candidacy. It found that Pearson’s application substantially complied with the statutory requirements, and any minor irregularities did not mislead the electors. The court also upheld the circuit court’s decision to deny the motion to disqualify Flatgard, finding no conflict of interest as the Board and the election commission were not adverse parties in this matter. The court concluded that the Board’s decision was supported by substantial evidence and was within its discretionary power. View "Brown v. Madison County Board of Supervisors" on Justia Law

The case involves a dispute between several plaintiffs, who are foreign nationals participating in an au pair program, and Cultural Care, Inc., a Massachusetts company that places au pairs with host families in the U.S. The plaintiffs allege that Cultural Care violated their rights under the Fair Labor Standards Act (FLSA) and various state wage and hour laws by failing to pay them legal wages. They also claim violations of state deceptive trade practices laws.The United States District Court for the District of Massachusetts denied Cultural Care's motion to dismiss the complaint, including its defense of derivative sovereign immunity under Yearsley v. W.A. Ross Construction Company. Cultural Care appealed, but the United States Court of Appeals for the First Circuit affirmed the District Court's decision, concluding that Cultural Care had not established entitlement to protection under Yearsley. After the case returned to the District Court, Cultural Care filed a motion to compel arbitration based on agreements in contracts signed by the au pairs with International Care Ltd. (ICL), a Swiss company. The District Court denied this motion, ruling that Cultural Care had waived its right to compel arbitration and that it could not enforce the arbitration agreement as a nonsignatory.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's denial of the motion to compel arbitration. The court held that Cultural Care, as a nonsignatory to the ICL Contract, could not enforce the arbitration agreement under either third-party beneficiary theory or equitable estoppel. The court emphasized that the arbitration agreement did not demonstrate with "special clarity" that the signatories intended to confer arbitration rights on Cultural Care. Additionally, the plaintiffs' statutory claims did not depend on the ICL Contract, making equitable estoppel inapplicable. View "Posada v. Cultural Care, Inc." on Justia Law

Rhonna Tindall slipped on a layer of ice in a parking lot owned by the County of Nevada and injured her knee. She sued the County, alleging that the icy parking lot was a dangerous condition of public property under Government Code sections 830 and 835. The County moved for summary judgment, claiming immunity under section 831, which provides that a public entity is not liable for injuries caused by weather conditions affecting the use of streets and highways.The trial court granted the County’s motion for summary judgment, ruling that the parking lot was a “street” or “highway” within the meaning of section 831, and that the County was entitled to “weather immunity.” The court also found that a reasonably careful person would have anticipated the potential existence of slippery ice in the parking lot. Tindall appealed, arguing that section 831 immunity does not apply to parking lots, that the dangerous condition resulted from a combination of weather and other factors, and that the County did not meet its burden to show that a reasonably careful person would have anticipated the ice.The California Court of Appeal, Third Appellate District, reviewed the case. The court concluded that the parking lot is a “street” within the meaning of section 831, largely based on the Vehicle Code’s definition of “street” as a publicly maintained place open to the public for vehicular travel. The court found Tindall’s arguments unpersuasive and determined that the County was not liable for her injury caused by the weather condition. The court also held that Tindall’s arguments regarding the combination of weather with other factors and the reasonably careful person standard were forfeited on appeal. The judgment of the trial court was affirmed. View "Tindall v. County of Nevada" on Justia Law

Environmental organizations challenged the EPA's decision not to revise technology-based pollution limits, guidelines, and standards (ELGs) for seven specific industrial categories under the Clean Water Act (CWA). The petitioners argued that the ELGs for these categories were outdated and did not reflect advances in pollution control technology.The EPA's decision was based on its Effluent Guidelines Program Plan 15, which used a Category Ranking Analysis to prioritize ELGs for revision. This analysis ranked industries based on the concentration and total load of pollutants discharged, using data from discharge monitoring reports (DMR data) from direct dischargers. The EPA did not consider data from indirect dischargers or unregulated pollutants in this analysis. The EPA concluded that revising the ELGs for the seven categories was not a priority based on this analysis.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the EPA's refusal to revise the ELGs constituted final agency action and was reviewable under the Administrative Procedure Act (APA). The court found that the EPA's reliance on the Category Ranking Analysis was arbitrary and capricious because it failed to consider advances in pollution control technology, pretreatment standards for indirect dischargers, and unregulated pollutants. The court also found that the EPA's decision regarding the plastics molding and forming category was arbitrary and capricious due to inadequate explanation.The court granted the petition for review in part, remanding the case to the EPA to reconsider its decision or provide a fuller explanation. The court emphasized that the EPA must offer a reasoned justification for its decisions consistent with the CWA and APA. View "Waterkeeper Alliance v. Environmental Protection Agency" on Justia Law

Interim Storage Partners (ISP) applied for a license to build a facility in West Texas to store spent nuclear fuel. During the licensing process, a Texas government agency and Fasken Land and Minerals, a private business, submitted comments on the draft environmental impact statement prepared by the Nuclear Regulatory Commission (NRC). Fasken also sought to intervene in the licensing proceeding but was denied by the NRC. Fasken challenged this denial before the full Commission and the D.C. Circuit but was unsuccessful.In September 2021, the NRC granted ISP a license to build and operate the storage facility. Texas and Fasken sought review of the NRC's licensing decision in the Fifth Circuit. The Fifth Circuit vacated ISP's license, allowing Texas and Fasken to challenge the NRC's decision despite not being parties to the licensing proceeding.The Supreme Court of the United States reviewed the case and held that Texas and Fasken were not entitled to judicial review of the NRC's licensing decision because they were not parties to the Commission's licensing proceeding. The Court emphasized that under the Hobbs Act, only a "party aggrieved" by a licensing order of the Commission may seek judicial review. To qualify as a party, one must be the license applicant or have successfully intervened in the proceeding. Since Texas and Fasken did not meet these criteria, they could not obtain judicial review. The Supreme Court reversed the Fifth Circuit's decision and remanded the case with instructions to deny or dismiss the petitions for review. View "Nuclear Regulatory Commission v. Texas" on Justia Law

The case involves the Environmental Protection Agency (EPA) and its denial of small refinery exemption petitions under the Clean Air Act's (CAA) renewable fuel program. The CAA requires most domestic refineries to blend renewable fuels into transportation fuels, with a phased exemption scheme for small refineries. Following a Supreme Court decision in HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn., the EPA reconsidered and ultimately denied 105 exemption petitions in 2022, based on its interpretation of "disproportionate economic hardship" and an economic theory that Renewable Identification Number (RIN) costs are passed through to consumers.The small refineries challenged these denials in multiple regional Circuits. Most Circuits either dismissed the challenges for improper venue or transferred them to the D.C. Circuit. However, the Fifth Circuit retained jurisdiction, ruling that the EPA's actions were locally applicable and not based on determinations of nationwide scope or effect, as the EPA still examined refinery-specific facts before issuing denials.The Supreme Court of the United States reviewed the case and held that the EPA's denials of small refinery exemption petitions are locally or regionally applicable actions that fall within the "nationwide scope or effect" exception, requiring venue in the D.C. Circuit. The Court concluded that the EPA's interpretation of "disproportionate economic hardship" and its RIN passthrough theory were determinations of nationwide scope or effect that formed the core basis for the denials. Therefore, the Fifth Circuit erred in retaining jurisdiction, and the case was vacated and remanded for further proceedings consistent with this opinion. View "Environmental Protection Agency v. Calumet Shreveport Refining, L.L.C." on Justia Law

A jurisdictional dispute arose between the International Longshore and Warehouse Union (ILWU) and the International Association of Machinists and Aerospace Workers (IAM) over maintenance work at SSA Terminals in the Port of Seattle. Both unions claimed the right to perform the work under their respective collective bargaining agreements. SSA initially assigned the work to ILWU, but IAM threatened economic action, prompting SSA to seek a resolution from the National Labor Relations Board (NLRB). The NLRB assigned the work to IAM, leading ILWU to pursue a grievance against SSA, which an arbitrator upheld.SSA then filed an unfair labor practice charge against ILWU, alleging that ILWU's pursuit of the grievance violated section 8(b)(4)(D) of the National Labor Relations Act. ILWU defended itself by invoking the work-preservation defense, which protects primary union activity. The NLRB rejected this defense, stating it was not applicable in pure jurisdictional disputes where multiple unions have valid contractual claims. The NLRB ordered ILWU to cease and desist from pursuing the maintenance work at Terminal 5.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the NLRB's position was foreclosed by its previous decision in International Longshore and Warehouse Union v. NLRB (Kinder Morgan), which established that a valid work-preservation objective provides a complete defense against alleged violations of section 8(b)(4)(D). The court vacated the NLRB's order and remanded the case for the NLRB to evaluate the merits of ILWU's work-preservation defense. The court also denied the petitions for review by IAM and the NLRB's cross-petition for enforcement. View "International Longshore and Warehouse Union v. National Labor Relations Board" on Justia Law