Justia Government & Administrative Law Opinion Summaries

The case involves a challenge to Montana House Bill 702 (HB 702), which prohibits discrimination based on vaccination status. Plaintiffs, including health care providers and individuals with compromised immune systems, argued that HB 702 is preempted by the Americans with Disabilities Act (ADA) and the Occupational Health and Safety Act (OSH Act) and violates the Equal Protection Clause of the Fourteenth Amendment. They sought to invalidate HB 702 in all health care settings, claiming it prevents employers from knowing employees' vaccination status, thus hindering ADA-required accommodations and OSH Act compliance.The United States District Court for the District of Montana ruled in favor of the plaintiffs, holding that HB 702 is preempted by the ADA and the OSH Act and violates the Equal Protection Clause. The court issued a permanent injunction against the enforcement of HB 702 in health care settings, reasoning that the law conflicts with federal requirements for reasonable accommodations and workplace safety.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision and vacated the injunction. The Ninth Circuit held that neither the ADA nor the OSH Act facially preempts HB 702 in health care settings. The court found that the plaintiffs did not demonstrate a genuine conflict between HB 702 and the ADA or OSH Act in any specific case, much less in all health care settings. The court also held that HB 702 does not violate the Equal Protection Clause, as the classification and differential treatment of facilities could rationally reflect Montana's interest in balancing personal privacy and public health.The Ninth Circuit reserved judgment on whether the ADA and the OSH Act could preempt HB 702 on a narrower, as-applied basis in future cases. The court deemed moot the portion of the district court's order related to interim CMS regulations, as those regulations have been rescinded. The court concluded that HB 702 is not facially invalid under the ADA, OSH Act, or Equal Protection Clause and vacated the district court's injunction in full. View "MONTANA MEDICAL ASSOCIATION V. KNUDSEN" on Justia Law

The State of Wyoming owns a 3.37-acre parcel in Uinta County, leased to Pilot Corporation for operating a truck stop. The property, held for the benefit of the Wyoming State Hospital, generates revenue for the hospital through the lease. In 2022, the Uinta County Assessor assessed the property for taxation, which the State contested, claiming the property was used primarily for a governmental purpose and thus exempt from taxation.The County Board of Equalization initially ruled in favor of the State, stating the property was used for a governmental purpose because the Board of Land Commissioners had a fiduciary duty to generate revenue for the hospital. However, the State Board of Equalization reversed this decision, holding that the Department of Revenue’s rules, which state that governmental property used by a lessee for non-governmental purposes is not tax-exempt, were binding. The district court affirmed the State Board’s decision, agreeing that the lessee’s use of the property for a truck stop did not constitute a governmental purpose.The Wyoming Supreme Court reviewed the case and affirmed the district court’s ruling. The Court held that the property was not exempt from taxation because it was used by the lessee, Pilot Corporation, for a non-governmental purpose. The Court emphasized that the end use of the property by the lessee determines its tax status, not the purpose of the lease. Additionally, the Court found that the legislature had not provided an exemption for such properties, as required by the Wyoming Constitution. Therefore, the property was subject to taxation. View "State of Wyoming v. Uinta County Assessor" on Justia Law

A group called Moms for Liberty, along with several individual members, filed a lawsuit against Brevard Public Schools and members of the Brevard County School Board. The plaintiffs claimed that their speech was unconstitutionally restricted at school board meetings. They argued that the Board's policies prohibiting "abusive," "personally directed," and "obscene" speech were unconstitutional. The plaintiffs sought declaratory and injunctive relief, as well as nominal damages.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Board. The district court concluded that the plaintiffs lacked standing because they could not show an actual or imminent injury. It also held that the Board's policies did not objectively chill the plaintiffs' protected speech. Despite finding no standing, the district court went on to rule that the Board's policies were constitutional.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The Eleventh Circuit found that the plaintiffs had standing to seek both retrospective and prospective relief. The court held that the Board's policy on "abusive" speech was unconstitutional because it was viewpoint-based and prohibited offensive speech. The policy on "personally directed" speech was also found to be unreasonable and inconsistently enforced, making it unconstitutional. Lastly, the court ruled that the prohibition on "obscene" speech was unreasonably applied to restrict protected speech, particularly when it involved reading from books available in school libraries. The case was remanded for further proceedings consistent with the Eleventh Circuit's opinion. View "Moms for Liberty v. Brevard Public Schools" on Justia Law

In 2018, Campaign Legal Center (CLC) filed an administrative complaint with the Federal Election Commission (FEC) alleging that 45Committee, Inc. violated the Federal Election Campaign Act by not registering as a political committee. After nearly two years of inaction by the FEC, CLC sued the FEC, seeking a declaration that the FEC's failure to act was "contrary to law." The court agreed and ordered the FEC to act within thirty days. When the FEC did not appear to act within that period, the court allowed CLC to bring a citizen suit against 45Committee.The United States District Court for the District of Columbia initially found that the FEC had failed to act on CLC's complaint and issued a default judgment against the FEC. The court ordered the FEC to act within thirty days, but the FEC did not notify the court or CLC of any action taken. Consequently, the court allowed CLC to bring a citizen suit against 45Committee. However, it later emerged that the FEC had held a reason-to-believe vote within the thirty-day period, which failed to garner the necessary votes to proceed with an investigation or dismiss the complaint.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and concluded that the district court was correct in dismissing CLC's citizen suit. The appellate court held that the FEC's holding of a reason-to-believe vote within the thirty-day period constituted conformance with the contrary-to-law determination. Therefore, the preconditions for bringing a citizen suit were not met, as the FEC had taken the required action by holding the vote, even though the vote did not result in a decision to investigate or dismiss the complaint. The court affirmed the district court's dismissal of the citizen suit. View "Campaign Legal Center v. 45Committee, Inc." on Justia Law

In 2008, Charles Anthony Giovinco pleaded guilty to enticement of a minor and possession of child pornography. He received concurrent sentences of 235 months for enticement and 120 months for possession. The First Step Act of 2018 (FSA) allows eligible prisoners to earn time credits for participating in certain programs, but excludes those serving sentences for specific offenses, including possession of child pornography.Giovinco argued that he should be eligible for FSA time credits after completing the sentence for the ineligible offense. The Bureau of Prisons (BOP) denied his request, stating that his entire term of imprisonment must be considered as a single, aggregated sentence, making him ineligible for FSA time credits. Giovinco filed a habeas petition, which the United States District Court for the District of Connecticut denied, deferring to the BOP's interpretation.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that under 18 U.S.C. § 3584(c), multiple terms of imprisonment must be treated as a single, aggregate term for administrative purposes, including the administration of FSA time credits. Therefore, a prisoner serving any part of an aggregated sentence for an ineligible offense is not eligible to earn FSA time credits. The court affirmed the district court's judgment, agreeing that the BOP correctly aggregated Giovinco's sentences and determined his ineligibility for FSA time credits. View "Giovinco v. Pullen" on Justia Law

Reabold California LLC applied to convert a former oil well into a Class II injection well in the Brentwood Oil Field, Contra Costa County. The well, drilled in 1963, had been used to pump oil and water from an aquifer. Reabold proposed minor modifications to the well to inject produced water back into the aquifer, which had been exempted from the Safe Drinking Water Act. The project aimed to eliminate the need for trucking the produced water to a disposal site. The California Department of Conservation’s Division of Geologic Energy Management (CalGEM) approved the project, invoking a Class 1 categorical exemption under the California Environmental Quality Act (CEQA) for minor alterations involving negligible or no expansion of use.The Contra Costa County Superior Court ruled in favor of Sunflower Alliance, which challenged CalGEM’s use of the categorical exemption. The court agreed with Sunflower that converting the well to an injection well constituted a significant change in use, thus not fitting within the Class 1 exemption. Consequently, the court issued a writ of mandate directing CalGEM to set aside its notice of exemption and project approval.The California Court of Appeal, First Appellate District, reviewed the case and reversed the lower court’s decision. The appellate court held that the well conversion project fell within the Class 1 exemption because the physical modifications were minor and the change in use posed negligible environmental risks. The court emphasized that the project involved injecting water into the same aquifer from which it was originally pumped, and regulatory conditions ensured the injected water would be confined within the aquifer. The court directed the lower court to deny Sunflower’s petition for writ of mandate and to order CalGEM to reinstate its project approval and notice of exemption. View "Sunflower Alliance v. Dept. of Conservation" on Justia Law

The Boeing Company filed a complaint against the United States, challenging a contracting officer's decision that required Boeing to pay over $1 million due to changes in its cost accounting practices. Boeing argued that the government's demand violated the relevant Federal Acquisition Regulation (FAR) and Cost Accounting Standards (CAS) provisions, which should offset increased costs with decreased costs, resulting in no net increase. Boeing's complaint included three contract claims and an illegal exaction claim.The United States Court of Federal Claims dismissed Boeing's contract claims without prejudice, stating it lacked jurisdiction to review the validity of the regulation under the Administrative Procedure Act (APA). The court also dismissed the illegal exaction claim with prejudice, despite acknowledging jurisdiction, because it believed it lacked the authority to consider the claim under the Contract Disputes Act (CDA).The United States Court of Appeals for the Federal Circuit reversed the lower court's decision. The appellate court held that the Court of Federal Claims has jurisdiction under the CDA to resolve the contract dispute, including the validity of the underlying regulation. The court also held that the Court of Federal Claims has jurisdiction over Boeing's illegal exaction claim under the Tucker Act, 28 U.S.C. § 1491(a)(1), and that the CDA does not preclude this jurisdiction. The case was remanded for further proceedings consistent with these holdings. View "BOEING COMPANY v. US " on Justia Law

Hung Huu Quoc Nguyen challenged the United States Citizenship and Immigration Services’ (USCIS) revocation of its approval of his EB-3 visa petition. An EB-3 visa allows noncitizens performing unskilled labor with a full-time job offer to work in the U.S. and potentially adjust their status to permanent resident. Nguyen’s employer, Muy Pizza Tejas, LLC, filed an I-140 petition on his behalf, which was later approved. However, after Muy Pizza sold the restaurant employing Nguyen to Ayvaz Pizza, USCIS issued a Notice of Intent to Revoke the approval, citing concerns about Muy Pizza’s ability to pay Nguyen’s wages and the validity of the numerous I-140 petitions it had filed.The United States District Court for the Southern District of Texas dismissed Nguyen’s case for lack of subject matter jurisdiction, holding that the claims amounted to a challenge of an unreviewable discretionary decision by USCIS. Nguyen appealed, arguing that his I-140 petition met the portability provision requirements under 8 U.S.C. § 1154(j), which should have prevented USCIS from revoking the petition. He also claimed that USCIS made procedural errors, including failing to make a successor-in-interest determination regarding Ayvaz Pizza.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court held that the portability provision did not apply to Nguyen’s I-140 petition because it was invalid from the start due to Muy Pizza’s failure to prove its ability to pay Nguyen’s wages. Consequently, the court found that USCIS’s revocation of the petition was a discretionary decision not subject to judicial review. Additionally, the court determined that Nguyen did not establish any specific procedural errors by USCIS that would warrant judicial review. The judgment of the district court was affirmed. View "Nguyen v. Jaddou" on Justia Law

Eight former public-school teachers who retired from the Keene School District between 2012 and 2017 sought review of a decision by the New Hampshire Retirement System (NHRS) Board of Trustees. They challenged the board's denial of their petitions for contribution and earnable compensation adjustment, arguing that the board erroneously found they consented to a 120-day delay in payment of early retirement stipends.The NHRS Board of Trustees had denied the petitions based on the finding that the petitioners consented to the delay in stipend payments. The board's decision was influenced by the fact that the petitioners did not file grievances or inquire with the NHRS about the delay at the time of their retirement. The board distinguished these petitioners from others who had successfully challenged the delay through grievances.The Supreme Court of New Hampshire reviewed the case and concluded that the petitioners could not have consented to the delay because the collective bargaining agreements (CBAs) did not authorize such a delay. The court noted that employees governed by a CBA cannot consent to terms that modify the agreement. The court also found that the petitioners were not at fault for the delay, as they were not informed that the delay would affect their pension calculations and had no reason to challenge the School District's policy at the time. Consequently, the court reversed the board's decision and remanded the case for proceedings consistent with its opinion. View "Petition of Retired Keene School Teachers" on Justia Law

Columbia Gas of Ohio, Inc. applied to the Ohio Power Siting Board for approval to construct a 3.7-mile natural-gas-distribution pipeline in Maumee, Ohio. The application was submitted under an accelerated review process for pipelines less than five miles long. Yorktown Management, L.L.C., which owns property adjacent to the proposed pipeline route, raised concerns about the safety and environmental impact of the pipeline, particularly its proximity to their commercial office building.The Ohio Power Siting Board approved Columbia's application under the accelerated review process, finding that the project met the necessary criteria. Yorktown filed a motion to intervene and later a motion to suspend the review, arguing that the board had not adequately addressed their safety concerns. The board denied Yorktown's motion to suspend and subsequently denied their application for rehearing, leading Yorktown to appeal the decision.The Supreme Court of Ohio reviewed the case and affirmed the board's decision. The court found that Columbia's application did not require a 50-foot-wide permanent easement along the entire pipeline route, as Yorktown claimed. The court also determined that Yorktown had waived its right to challenge the board's rejection of testimony from a different pipeline project. Additionally, the court held that the board did not err in refusing to suspend its review of the accelerated application, as Yorktown failed to demonstrate good cause for suspension. The court concluded that the board did not improperly defer to Columbia and had appropriately conditioned the approval on compliance with relevant safety regulations. View "In re Letter of Notification Application of Columbia Gas of Ohio, Inc. for the Ford Street Pipeline Project" on Justia Law