Justia Government & Administrative Law Opinion Summaries

Rosa A. Camacho, a retired Class II member of the Northern Mariana Islands Retirement Fund, claimed that she was entitled to cost-of-living allowances (COLAs) as part of her retirement benefits. When Camacho entered the Retirement Fund in 1980, COLAs were not part of the retirement package. In 1989, the Commonwealth legislature amended the Retirement Fund Act to provide a two percent COLA. Over the years, this provision was repeatedly modified, suspended, and ultimately repealed in 2011. The Commonwealth’s financial difficulties led to a class action and a subsequent settlement agreement in 2013, which entitled participants to 75% of their “Full Benefits,” as defined by statute or guaranteed by the Commonwealth Constitution.The United States District Court for the Northern Mariana Islands held that Camacho was not entitled to COLAs under the settlement agreement, reasoning that COLAs were not constitutionally protected benefits at the time she joined the Retirement Fund and were discretionary by statute as of 2013. Camacho appealed, arguing that the statutory introduction of COLAs during her membership created a protected right under Article III, section 20(a) of the Commonwealth Constitution.The United States Court of Appeals for the Ninth Circuit certified to the Supreme Court of the Commonwealth of the Northern Mariana Islands the question of whether section 8334(e) of the Retirement Fund Act conferred a constitutionally protected accrued benefit in the form of COLAs for Class II members employed when the Act took effect. The Commonwealth Supreme Court answered in the negative, finding that COLAs were legislative policy adjustments and not protected contractual benefits. In accordance with this interpretation, the Ninth Circuit held that Camacho did not acquire a constitutionally protected right to COLAs under section 8334(e). The district court’s decision was affirmed. View "Camacho v. Northern Mariana Islands Settlement Fund" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

A group of individuals who were instrumental in the campaign to incorporate the City of Erda sought to prevent approximately 8,000 acres from being annexed out of Erda and into Grantsville City. The controversy arose after an entity, Six Mile Ranch, initiated and amended an annexation petition to move land from Erda’s boundaries into Grantsville, during and after Erda’s incorporation process. The Grantsville City Recorder determined that the annexation petition met statutory requirements and certified it, which was followed by Grantsville approving the annexation by ordinance and entering a development agreement for the property. The sponsors challenged the annexation, alleging it violated both statutory requirements and constitutional provisions, and sought to invalidate the annexation ordinance and prevent the Lieutenant Governor from certifying it.In the Third District Court, Tooele County, the sponsors filed a petition for extraordinary relief under rule 65B of the Utah Rules of Civil Procedure. The district court dismissed the petition, concluding that the sponsors lacked statutory, traditional, and alternative standing to challenge the annexation, and denied related motions.On direct appeal, the Supreme Court of the State of Utah affirmed the dismissal but on alternative grounds. The court held that the sponsors, lacking statutory standing, had no other remedy for their statutory claims but failed to demonstrate that rule 65B(d)(2)(B) or the judiciary’s constitutional writ authority permitted relief where a public official had performed their statutory duty, albeit allegedly incorrectly. Regarding the constitutional claims, the court found that a plain, speedy, and adequate remedy was available through declaratory judgment actions, as clarified by recent appellate decisions. Therefore, the sponsors could not obtain extraordinary relief under rule 65B for either set of claims, and the dismissal was affirmed. View "Erda Community Association v. Baugh" on Justia Law

Tamica Rainey, a Chicago police officer, was injured in duty-related car accidents in 2013 and 2015. She was awarded duty disability benefits in 2017 based on injuries to her neck and shoulder. As required by statute, Rainey’s disability status was periodically reviewed, and in 2022, after multiple hearings and submissions of medical records, the Retirement Board of the Policemen’s Annuity and Benefit Fund of the City of Chicago discontinued her duty disability benefits, concluding she was no longer disabled from her duty-related injuries. However, when Rainey attempted to return to work, the police department determined she could not perform her duties.Rainey sought administrative review in the Circuit Court of Cook County, which reversed the Board’s decision, relying on precedent that an officer remains disabled if the department cannot provide a position with needed accommodations. The circuit court also awarded Rainey attorney fees and costs under section 5-228(b) of the Illinois Pension Code. The Board appealed, and the Appellate Court of Illinois, First District, affirmed both the restoration of Rainey’s benefits and the award of attorney fees and costs.The Supreme Court of Illinois reviewed the Board’s challenge to the attorney fees and costs award. The court held that section 5-228(b) of the Illinois Pension Code authorizes an award of attorney fees and costs not only to police officers who successfully challenge the initial denial of duty or occupational disease disability benefits, but also to those who successfully challenge the discontinuation of such benefits. The court rejected the Board’s argument that statutory attorney fee awards are limited to initial applications, finding the statute’s plain language and legislative intent favor such awards for both denial and discontinuation challenges. The Supreme Court affirmed the judgments of the appellate and circuit courts and reversed the Board’s decision. View "Rainey v. Retirement Board of the Policemen & Annuity and Benefit Fund of the City of Chicago" on Justia Law

An 18-year-old driver, Elijah Henry, collided with Melanie Gilliland’s vehicle after running a red light, causing her severe injuries. At the time of the accident, Henry was being followed by Officer Matthew Harvey of the City of Pleasanton Police Department. Officer Harvey had entered a parking lot to investigate possible vehicle break-ins and, upon seeing Henry’s car leave the lot, made a U-turn to follow it. Henry, who had smoked marijuana earlier, accelerated away, fearing police interaction but denying any belief that he was being pursued for arrest. Officer Harvey did not activate his lights or siren and testified that he did not initiate a pursuit under the City’s vehicular pursuit policy.Gilliland sued both Henry and the City for negligence. The City asserted immunity under California Vehicle Code section 17004.7, which protects public entities from liability for damages caused by fleeing suspects if the entity has a compliant vehicular pursuit policy and provides regular training. The Alameda County Superior Court initially denied the City’s motion for summary judgment, finding that neither an actual nor perceived pursuit occurred under the City’s policy definition. However, after a bench trial before a different judge, the court found the City immune, interpreting “pursued” in the statute according to its ordinary meaning rather than the policy’s definition, and concluded Henry believed he was being pursued.The California Court of Appeal, First Appellate District, Division One, reviewed the case and held that the definition of “pursuit” in the public entity’s vehicular pursuit policy governs both actual and perceived pursuits under section 17004.7. The court found the trial court erred by applying the ordinary meaning of “pursued” and reversed the judgment, remanding for further proceedings using the correct legal standard. The main holding is that statutory immunity under section 17004.7 depends on the policy’s definition of pursuit, not the word’s general meaning. View "Gilliland v. City of Pleasanton" on Justia Law

A Concord police officer discovered her firearm missing from the station’s lockers in 2013. Investigation revealed that another officer, the plaintiff, had mistakenly taken the firearm while transporting a prisoner to a hospital. The plaintiff gave inconsistent accounts about when she realized the mistake, telling supervisors she noticed it at the station, while her partner reported she only realized it at the hospital. An internal affairs investigation found the plaintiff’s statements lacked credibility and concluded she had lied to colleagues and supervisors about the incident. The police chief sustained these findings, terminated her employment, and submitted her name for inclusion on the Exculpatory Evidence Schedule (EES), formerly known as the “Laurie List.”The plaintiff appealed her termination to the City of Concord’s Personnel Appeals Board, which upheld the decision, finding her lacked credibility. She then filed a complaint in the Superior Court alleging gender discrimination and wrongful termination, which was settled. The settlement required the City to remove documents related to the incident from her personnel file and maintain them in a separate investigative file, and to report her departure as a negotiated resignation.Years later, the plaintiff sued the City and the New Hampshire Department of Justice in Superior Court, seeking removal of her name from the EES under RSA 105:13-d. She argued the alleged misconduct was immaterial, the records were no longer in her personnel file, and her inclusion on the EES was unwarranted given the passage of time. The Superior Court granted summary judgment for the defendants.The Supreme Court of New Hampshire affirmed, holding that RSA 105:13-d governs EES inclusion and applies to “personnel information,” not just personnel files. The court found the plaintiff’s untruthfulness constituted potentially exculpatory evidence and that it was reasonably foreseeable her misconduct could be admissible to impeach her credibility if she were called as a witness in a future case. View "Doe v. Concord Police Department" on Justia Law

A man brought a civil lawsuit against the Philadelphia District Attorney and several assistant district attorneys, alleging they violated Pennsylvania’s Wiretap Act by using and disclosing surreptitiously recorded conversations between him and his ex-wife during a criminal prosecution. The recordings, made by his ex-wife without his knowledge during their marriage, were provided to the police and used by prosecutors in their attempt to bring criminal charges against him. The criminal court ultimately found the recordings were obtained in violation of the Wiretap Act and barred their use as evidence, leading to the dismissal or withdrawal of all charges.In the Court of Common Pleas of Philadelphia County, the prosecutors raised the defense of high public official immunity in response to the civil suit for damages under the Wiretap Act. The trial court agreed, holding that the General Assembly had only waived sovereign immunity in the Wiretap Act, not high public official immunity, and dismissed the claims with prejudice. On appeal, the Commonwealth Court affirmed, reasoning that high public official immunity is a broad, absolute bar to civil suits for damages arising from actions taken within the scope of official duties, and that the Wiretap Act did not expressly waive this immunity for district attorneys or their assistants.The Supreme Court of Pennsylvania reviewed whether law enforcement officers, specifically district attorneys and assistant district attorneys, are immune from civil suits for damages under Section 5725 of the Wiretap Act. The court held that, while the Act expressly waives sovereign immunity, it does not specifically and explicitly waive high public official immunity. Therefore, district attorneys and assistant district attorneys retain high public official immunity from civil suits for damages under the Wiretap Act when acting within the scope of their official duties. The Supreme Court of Pennsylvania affirmed the order of the Commonwealth Court. View "Winig v. Office of DA of Philadelphia" on Justia Law

A group called Montanans for Nonpartisan Courts (MNC) submitted a proposed constitutional initiative, CI-132, which would add a section to the Montana Constitution stating that judicial elections shall remain nonpartisan. MNC also submitted a proposed ballot statement: “CI-132 amends the Montana Constitution to require that judicial elections remain nonpartisan.” After the initiative and statement were submitted to the Secretary of State and reviewed by the Legislative Services Division, the Montana Attorney General conducted a legal sufficiency review. The Attorney General found the initiative legally sufficient but rejected MNC’s proposed statement, arguing it did not accurately reflect the current constitutional text and failed to define “nonpartisan.” The Attorney General then issued a revised statement, which MNC challenged as misleading and prejudicial.MNC filed an original proceeding in the Supreme Court of the State of Montana, seeking a declaratory judgment that the Attorney General’s revised statement violated statutory requirements and asking the Court to certify its own proposed statement. The Attorney General responded, defending his revised statement and criticizing MNC’s version for not reflecting the constitutional status quo and lacking a definition of “nonpartisan.”The Supreme Court of the State of Montana held that the Attorney General’s revised statement was misleading because it implied CI-132 would change the status quo, when in fact judicial elections in Montana are already nonpartisan by statute. The Court also found that a definition of “nonpartisan” was unnecessary, given voters’ familiarity with the term and the absence of a statutory definition. The Court concluded that MNC’s proposed statement was a true and impartial explanation of the initiative in plain language, meeting statutory requirements. The Court certified MNC’s statement to the Secretary of State and granted the petition for declaratory judgment. View "Montanans for Nonpartisan Courts v. Knudsen" on Justia Law

Anton’s Services Inc. was a subcontractor on two public works projects in San Diego: the Torrey Pines Road Project and the Voltaire Street Project. On both projects, Anton’s classified its workers under the “Tree Maintenance” prevailing wage category, paying them accordingly. The Division of Labor Standards Enforcement (DLSE) investigated and determined that Anton’s work was construction-related and should have been classified under the “Laborer (Engineering Construction)” category, which carries a higher prevailing wage. Additionally, Anton’s failed to comply with apprenticeship requirements, including submitting contract award information, employing the required ratio of apprentices, and requesting apprentices from local committees.After the DLSE issued civil wage and penalty assessments for both projects, Anton’s challenged these findings in administrative proceedings before the Director of Industrial Relations. The parties submitted stipulated facts and documentary evidence. The Director affirmed the DLSE’s assessments, finding Anton’s had misclassified workers, underpaid prevailing wages, failed to comply with apprenticeship requirements, and was liable for penalties and liquidated damages. The Director also found Anton’s violations were willful, given its prior record and lack of prompt correction.Anton’s then sought judicial review in the Superior Court of San Diego County through a petition for writ of administrative mandamus. The trial court, applying the substantial evidence standard, upheld the Director’s decision and rejected Anton’s attempt to introduce extra-record evidence.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed the administrative record for substantial evidence. The court affirmed the trial court’s judgment, holding that Anton’s misclassified workers, underpaid prevailing wages, failed to comply with apprenticeship requirements, and was properly assessed penalties and liquidated damages. The court clarified that liquidated damages are owed until wages are actually paid to workers, not merely withheld by a contractor. The judgment was affirmed. View "Anton's Services v. Hagen" on Justia Law

A group of Maine lobstermen challenged a state rule requiring all federally permitted lobster fishers to install electronic tracking devices on their vessels, which transmit GPS location data whenever the vessels are in the water. This rule was adopted by the Maine Department of Marine Resources (MDMR) to comply with an addendum to the Atlantic States Marine Fisheries Commission’s American Lobster Fishery Management Plan. The addendum aimed to reduce risks to North Atlantic right whales, improve fishery data, and support regulatory enforcement. The tracking devices must remain powered and transmit data at all times, including when vessels are docked or used for personal purposes.The plaintiffs filed suit in the United States District Court for the District of Maine, arguing that the MDMR Rule violated their rights under the Fourth Amendment, as well as equal protection and state administrative law. The district court granted the state’s motion to dismiss, holding that the plaintiffs failed to state a claim under the Fourth Amendment because the lobster fishery is a closely regulated industry and the rule was not unreasonably invasive. The court noted several concessions by the parties, including that the GPS tracking constituted a search, that the lobster industry is closely regulated, and that the search was administrative in nature.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that the lobster industry is a closely regulated industry and that the administrative search exception, as articulated in New York v. Burger, 482 U.S. 691 (1987), applied. The court found that the MDMR Rule satisfied the Burger test: it served a substantial government interest, warrantless searches were necessary to the regulatory scheme, and the rule provided a constitutionally adequate substitute for a warrant. The First Circuit affirmed the district court’s dismissal. View "Thompson v. Wilson" on Justia Law