Justia Government & Administrative Law Opinion Summaries

The case involved two separate lawsuits against the City of New York, where the plaintiffs, Luis Jaime and Adan Orozco, were seeking permission to serve late notices of claim for alleged intentional torts committed by City employees. The claims were based on the General Municipal Law § 50-e (5), which allows for late notices if the court believes the City has actual knowledge of the essential facts constituting the claims.In Orozco's case, he claimed that officials of the New York City Police Department (NYPD) and the District Attorney's Office obtained a warrant for his arrest without probable cause and used false evidence. Jaime, who was detained at Riker's Island, alleged that he was attacked by correction officers and/or inmates on multiple occasions. Both plaintiffs argued that the City had actual knowledge of their claims due to the involvement of its employees and its possession of related records.The Court of Appeals disagreed with the lower courts' decision to grant the plaintiffs leave to serve late notices of claim. It held that mere participation of City's employees in an intentional tort and the City's possession of related records do not necessarily provide the City with actual knowledge of the essential facts of the claims. The court found that both plaintiffs failed to provide substantive evidence to establish the City's actual knowledge. It also found that their reasons for late filing, such as defending against criminal charges and the effects of the COVID-19 pandemic, did not constitute a reasonable excuse. Consequently, the Court of Appeals reversed the orders of the Appellate Division, denying the plaintiffs' petitions to file late notices of claim. View "Matter of Jaime v City of New York" on Justia Law

This case involves a dispute between a grain producer, Robert Miller, and the Illinois Department of Agriculture over compensation from the Illinois Grain Insurance Fund. The fund is intended to compensate grain producers for losses incurred when a licensed grain dealer or a licensed warehouseman fails. Miller made a claim with the Department after his grain dealer, SGI Agri-Marketing, LLC, failed before making payment under a “price later contract.”A key issue in the case was the interpretation of the Grain Code's provision concerning the pricing of grain under a “price later contract.” According to the Code, if such a contract is not signed by all parties within 30 days of the last date of delivery of grain intended to be sold by the contract, then the grain is automatically priced on the next business day after those 30 days, at the market price of the grain at the close of that day.Miller argued that the grain was priced when he signed a purchase confirmation, which was within the 160-day window before the failure of the dealer, thus entitling him to compensation from the fund. The Department contended that the Grain Code automatically priced the grain as a matter of law on the next business day after 30 days from the last grain delivery, as the parties had not signed a contract agreeing to a pricing formula by then.The Supreme Court of the State of Illinois agreed with the Department’s interpretation. It held that the statute was unambiguous and provided that the grain would be priced as a matter of law on the next business day after 30 days from the last delivery. Therefore, because the grain was priced outside the 160-day protection window prescribed by the Grain Code, Miller was not eligible for compensation from the fund. The Supreme Court affirmed the circuit court’s judgment and reversed the appellate court's judgment. View "Miller v. Department of Agriculture" on Justia Law

The primary issue in this complex case concerned a man, Ronnie Lehman, who was residing at a residential program called the Renewal Center as a condition of his parole. While there, he was discovered unresponsive due to a drug overdose, and a search revealed possession of illegal drugs. He was charged under Section 5123(a.2) of the Crimes Code, which prohibits a prisoner or inmate from unlawfully possessing a controlled substance. Lehman's legal team argued that he didn't qualify as an "inmate" under this law because he was on parole and voluntarily living at the Renewal Center.The Supreme Court of Pennsylvania disagreed, concluding that Lehman did qualify as an "inmate" under Section 5123(a.2), (e) of the Crimes Code at the time he unlawfully possessed a controlled substance. The court reasoned that the term "committed to" in the statute didn't necessarily imply forceful or involuntary commitment, and could encompass Lehman's situation where he agreed to reside at the Renewal Center as a part of his parole conditions. Therefore, the court held that the evidence was sufficient to sustain Lehman's conviction under Section 5123(a.2), and reversed the judgment of the Superior Court which had granted Lehman post-conviction relief. View "Commonwealth v. Lehman" on Justia Law

In the case before the Supreme Court of Ohio, the relator, Kimani Ware, an inmate, sought a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (“ODRC”), Trumbull Correctional Institution (“TCI”), and several of its employees, to respond to six of his public-records requests, and to award him statutory damages and court costs.Concerning each of the six requests, the respondents argued that they were not required to provide the requested records because Ware did not identify them as formal public-records requests. The court disagreed, stating that the Public Records Act does not require a requester to formally label a request as a “formal public records request”.Regarding the May 29, 2021 and October 6, 2021 requests, the court denied Ware's writ and the request for statutory damages, as the respondents had provided evidence that they provided the requested records. However, for the June 3, 2022 and June 19, 2022 requests, the court granted the writ and awarded Ware $1,000 in statutory damages for each request, as the respondents did not provide the requested documents.As for the June 5, 2022 and July 23, 2022 requests, the writ and the request for statutory damages were denied since Ware did not submit these two requests to the proper records custodians.Lastly, the court denied respondents’ motion to declare Ware a vexatious litigator, stating that respondents had not shown that Ware has “habitually, persistently, and without reasonable cause engage[d] in frivolous conduct". View "State ex rel. Ware v. Ohio Dept. of Rehab. & Corr." on Justia Law

In this case, the plaintiff, Ricky Pendleton, is an inmate in the West Virginia prison system who follows the "Sufi Original Traditions" of Islam. His religious beliefs require a diet that promotes "compassion and harmlessness to living creatures," which he interprets to mean a diet of "vegetables, fruits and certain fish." In 2014, prison officials introduced a new diet program for those with religious dietary restrictions. However, the program only offered one "religious special diet" designed to meet the needs of all faiths by following the rules of the most diet-restrictive ones. This diet used soy as its primary protein source, which Pendleton's body had problems digesting. Pendleton requested a religious accommodation, but this request was denied. He filed two grievances, which were also denied. Pendleton then filed a pro se complaint against three prison officials. The district court dismissed Pendleton’s complaint, concluding he had not adequately alleged he was being forced to consume any foods forbidden by his religion.The United States Court of Appeals for the Fourth Circuit vacated and remanded the district court's judgment. The court held that Pendleton had plausibly alleged that prison officials imposed a substantial burden on his religious practice by forcing him to choose between a government-provided benefit (the diet) and his religious convictions. The court also rejected the argument that Pendleton could obtain a meat-free and soy-free diet by obtaining test results showing he has a medically significant allergy to soy. The court concluded that Pendleton need not produce documentation of his alleged soy allergy to survive a motion to dismiss. Instead, it was enough that he had plausibly alleged that he cannot digest soy and that he suffered gastrointestinal distress after switching to the religious special diet. The court also held that Pendleton’s Free Exercise Clause claim and his motion to be severed from the prison’s diet program should be reconsidered by the district court. View "Pendleton v. Jividen" on Justia Law

In a case before the Supreme Court of the State of Montana, the Montana Environmental Information Center sued the Montana Department of Public Service Regulation, Public Service Commission, and Northwestern Corporation, also known as Northwestern Energy. The plaintiff contested Northwestern's failure to purchase energy from Community Renewable Energy Project (CREP) resources in 2015 and 2016. Northwestern, which is a public utility, had obtained waivers from the Commission for these obligations. The plaintiff claimed that Northwestern’s waivers were granted erroneously and sought penalties for Northwestern’s non-compliance.The District Court reversed the Commission's decision, concluding that Northwestern hadn't taken all reasonable steps to procure CREP resources for the years in question. The court also assessed a $2,519,800 penalty against Northwestern. On appeal, the Supreme Court of the State of Montana held that the District Court correctly reversed the Commission's waiver for 2015, but made an error in assessing the penalty. The Supreme Court affirmed the decision in part, vacated it in part, and remanded the case to the District Court for further proceedings. The court directed the District Court to remand the case to the Commission to assess the penalty against Northwestern for its non-compliance in 2015 and, if applicable, 2016. View "Montana Environmental Information Center v. Northwestern Energy" on Justia Law

This case involves a minor plaintiff, identified as S.W., who suffered severe injuries inflicted by her father's girlfriend. The State of Montana's Department of Public Health and Human Services was sued based on claims that it negligently failed to remove S.W. from her father's home prior to the injuries. The District Court ruled that the state's child abuse investigation was negligent and had led to S.W.'s injuries. A jury awarded S.W. over $16 million in damages.Several issues were raised on appeal, including whether the District Court was correct in deciding that the state's immunity provision did not cover the State, but only individual persons, whether the state was negligent as a matter of law, and whether the assault on S.W. was foreseeable.The Supreme Court of the State of Montana held that the District Court was correct in its interpretation that the state's immunity provision did not extend to the State. However, the Supreme Court found that the District Court erred in its summary judgment that the State was negligent as a matter of law and that the assault on S.W. was foreseeable as a matter of law. The Court ruled that these issues contained material factual disputes that should be left to a jury. The Supreme Court also held that the District Court abused its discretion by imposing a disproportionate sanction on the State for spoliation of evidence. The judgment was reversed, the jury’s verdict was vacated, and the case was remanded for a new trial. View "S. W. v. State" on Justia Law

In this case before the United States Court of Appeals for the Fifth Circuit, the plaintiff, Lebene Konan, alleged that the United States Postal Service (USPS) employees intentionally withheld her mail for two years. Konan, who is African American, owned two properties in Texas that she rented out to tenants. She claimed that USPS employees, Jason Rojas and Raymond Drake, deliberately failed to deliver mail to these residences because they didn't like the idea of a black person owning those properties.Konan filed a lawsuit under the Federal Tort Claims Act (FTCA) and also alleged violations of her equal protection rights. The district court dismissed her claims due to lack of subject matter jurisdiction and failure to state a claim. Konan appealed the decision.The Appeals Court affirmed in part and reversed in part. It ruled that the district court erred in dismissing Konan's FTCA claim, finding that the postal-matter exception to the FTCA's immunity waiver did not apply to intentional acts such as those alleged. The court ruled that Konan's claims did not constitute a "loss," "miscarriage," or "negligent transmission" of mail, which are covered by the exception, as they involved intentional non-delivery of mail.However, the court agreed with the district court's dismissal of Konan's equal protection claims. The court held that Konan did not provide sufficient facts to support her assertion that the USPS employees continued to deliver mail to similarly situated white property owners while denying her mail delivery. It also held that her claims were barred by the intracorporate-conspiracy doctrine, which precludes conspiracy claims against multiple defendants employed by the same governmental entity. Therefore, the court affirmed the dismissal of Konan's equal protection claims. View "Konan v. USPS" on Justia Law

The U.S. Court of Appeals for the Third Circuit ruled on a case involving the Consumer Financial Protection Bureau (CFPB) and a group of trusts associated with the National Collegiate Student Loan Trust. The central questions in the case were whether the trusts were "covered persons" under the Consumer Financial Protection Act (CFPA), and whether the CFPB was required to ratify the underlying action.The CFPB had initiated enforcement proceedings against the trusts for alleged violations related to servicing and collecting student loans, which the trusts had contracted out to third parties. The trusts argued that they were not "covered persons" under the CFPA and that the CFPB's action was untimely because it was initiated when the CFPB director was unconstitutionally insulated from presidential removal and ratified after the statute of limitations had expired.The Third Circuit held that the trusts were indeed "covered persons" under the CFPA because they were engaged in offering or providing a consumer financial product or service. The court also held that the CFPB was not required to ratify the action before the statute of limitations had run, following the Supreme Court's decision in Collins v. Yellen. The court concluded that there was no indication that the unconstitutional limitation on the President's authority to remove the CFPB Director harmed the Trusts, and thus no need for ratification. Therefore, the case was affirmed and remanded to the lower court for further proceedings with these determinations in mind. View "Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trust" on Justia Law

The United States Court of Appeals for the Tenth Circuit affirmed a lower court's ruling regarding a veteran, Bruce Hay, who was convicted of ten counts of stealing government property and six counts of wire fraud. The case centered around Hay's alleged exaggeration of his disability to gain benefits from the Department of Veterans Affairs (VA). The VA conducted a six-year investigation, even installing a pole camera that recorded Hay's daily activities outside his house for 68 days.Hay appealed his conviction on three grounds: insufficient evidence supporting his conviction, violation of his Fourth Amendment rights by the VA's installation of the pole camera, and wrongful admission of evidence by the district judge. The court rejected all three arguments.First, the court ruled that Hay's fraudulent acquisition of government property constituted "stealing" under 18 U.S.C. § 641 and that sufficient evidence was presented at trial to support his conviction for stealing government property and wire fraud.Second, the court held that the use of the pole camera did not constitute a search under the Fourth Amendment as it only captured his activities in public view.Lastly, the court rejected Hay's claim that evidence post-dating the charging period was improperly admitted, finding that the district court acted within its discretion.In conclusion, the court affirmed the district court's denial of a judgment of acquittal and the admission of contested evidence. View "United States v. Hay" on Justia Law