Justia Government & Administrative Law Opinion Summaries

N.S. was arrested for robbery and destruction of property and was released on his own recognizance by a Magistrate Judge. However, before he could leave the courthouse, U.S. Marshals detained him based on an ICE detainer. N.S. filed a class complaint alleging that the Marshals acted beyond their statutory authority by making a civil immigration arrest, violating the Administrative Procedure Act.The United States District Court for the District of Columbia certified the proposed class and granted N.S.'s request for a permanent injunction, prohibiting Marshal Dixon and his agents from arresting and detaining criminal defendants in the Superior Court for suspected civil immigration violations. The court held that the Marshals were not authorized to make civil immigration arrests as they had not undergone the required training. The court also found that the 2002 Order delegating authority to the Marshals lacked sufficient legal support.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Marshals were not authorized to make civil immigration arrests due to the lack of required training. However, the court found that the class-wide injunction issued by the district court was barred by 8 U.S.C. § 1252(f)(1), which prohibits lower courts from enjoining the operation of certain immigration provisions. The court vacated the injunction and remanded the case to the district court to reconsider the appropriate remedy. View "N.S. v. Dixon" on Justia Law

Brenda Zaragoza fell in the parking lot of a Johnson County public library, resulting in serious injuries. She sued the Johnson County Board of Commissioners, alleging negligence for failing to mitigate the presence of a storm drain and warn of the change in elevation between the curb and the parking surface. The district court granted summary judgment for the County, citing recreational use immunity under the Kansas Tort Claims Act (KTCA), which bars negligence claims arising from the use of public property intended for recreational purposes unless gross and wanton negligence is involved. The court also denied Zaragoza's motion to amend her petition to add a claim of gross and wanton negligence.The Kansas Court of Appeals affirmed the district court's decision, holding that the library's recreational use immunity applied and that the district court did not abuse its discretion in denying Zaragoza's untimely motion to amend her petition. Zaragoza then petitioned for review, raising both issues. After the petition was granted, she filed a supplemental brief raising a new constitutional argument, which was not considered because it was not presented in her petition for review or before the lower courts.The Kansas Supreme Court upheld the lower courts' decisions. The court declined to consider Zaragoza's unpreserved constitutional challenge. It affirmed the district court's grant of summary judgment, agreeing that the library's parking lot fell under the recreational use immunity provision of the KTCA. The court also affirmed the district court's denial of Zaragoza's motion to amend her petition, finding no evidence of gross and wanton negligence by the County. The court concluded that the library is public property intended for recreational purposes and that the parking lot is integral to its function, thus qualifying for immunity under the KTCA. View "Zaragoza v. Board of Johnson County Comm'rs " on Justia Law

American Oversight, a nonprofit group, filed a petition for a writ of mandamus in district court against the Governor and the Attorney General of Texas, alleging violations of the Public Information Act (PIA). They sought official communications and other documents, which the Governor's and Attorney General's offices partially withheld, citing various exemptions. Dissatisfied with the responses, American Oversight pursued legal action to compel the release of the information.The Travis County district court denied the State's pleas to the jurisdiction, leading to an interlocutory appeal. The State argued that the district court lacked jurisdiction to issue a writ of mandamus against constitutional executive officers, as only the Texas Supreme Court has such authority under section 22.002(c) of the Texas Government Code. The court of appeals affirmed the district court's decision, holding that section 552.321(b) of the PIA authorized district courts to issue mandamus relief against any governmental body, including those headed by constitutional executive officers.The Supreme Court of Texas reviewed the case and concluded that section 552.321(b) did not expand the jurisdiction of district courts to issue writs of mandamus against constitutional executive officers. The Court held that only the Texas Supreme Court has the authority to issue such writs against these officers, as per section 22.002(c) of the Texas Government Code. Consequently, the Supreme Court of Texas reversed the judgment of the court of appeals and directed the district court to dismiss the mandamus petition for lack of jurisdiction. View "PAXTON v. AMERICAN OVERSIGHT" on Justia Law

Eugene Sikora, a former prisoner, claims that the State of Iowa failed to release him from prison when his sentence was over. He was convicted of three felonies in 2016 and sentenced to concurrent five-year terms, which were suspended for probation. In 2017, his probation was revoked, and he was imprisoned until March 2019. Sikora alleges that due to a miscalculation, he was imprisoned for nearly five months longer than allowed, as the defendants did not credit him for 292 days served in county jails and a custodial residential center.Sikora filed a suit over three years after his release, seeking money damages for wrongful imprisonment. He named the State of Iowa and the director of the Iowa Department of Corrections as defendants, asserting five tort claims, including violations of his constitutional rights and negligence. The defendants moved to dismiss the suit, arguing sovereign immunity and other defenses. The district court dismissed some of Sikora’s claims but allowed others to proceed. However, after the Iowa Supreme Court's decision in Burnett v. Smith, which overruled the precedent allowing constitutional tort claims, the district court dismissed Sikora’s remaining claims and denied his motion to amend his petition to add new defendants and claims.The Iowa Supreme Court affirmed the district court’s dismissal, holding that sovereign immunity barred Sikora’s claims. The court concluded that all of Sikora’s claims were essentially false imprisonment claims, which are barred by sovereign immunity under Iowa Code section 669.14(4). The court also rejected Sikora’s arguments that constitutional torts and claims against individual state employees could proceed, emphasizing that the Iowa Tort Claims Act (ITCA) provides the exclusive mechanism for such claims and explicitly prohibits claims based on false imprisonment. View "Sikora v. State of Iowa" on Justia Law

Annette R. Deal served in the U.S. Navy and Army and filed a claim for compensation for Cushing’s syndrome and a nervous condition in 1991, which was denied in 1992. She received treatment within the appeal period, resulting in a 1993 medical record being added to her file. The VA did not address whether this record met the requirements to be considered new and material evidence until 2021. Mrs. Deal did not appeal the 1992 decision. She filed another claim in 1995, which was partially granted, and a third claim in 2003, leading to a 2016 decision granting service connection for her psychiatric disorder with an effective date of August 1, 2003.The Board of Veterans’ Appeals granted an effective date of March 10, 1995, for her psychiatric disorder, ruling that new and material evidence was presented in 1997. However, it denied an effective date of October 1991, ruling that the 1993 record was not material. Mrs. Deal appealed to the United States Court of Appeals for Veterans Claims, which affirmed the Board’s decision, finding a plausible basis for ruling that the 1993 record was not material.The United States Court of Appeals for the Federal Circuit reviewed the case. Mrs. Deal argued that the VA’s failure to address the 1993 record before the 2016 decision meant her 1991 claim remained open, entitling her to an earlier effective date. The court disagreed, stating that the VA’s delay does not automatically entitle a claimant to an earlier effective date unless the evidence is determined to be new and material. The court affirmed the Veterans Court’s decision, holding that the 1993 record was not material and the 1992 decision was final. View "Deal v. Collins" on Justia Law

The case involves members of the Auburn University Board of Trustees and various Auburn University employees (defendants) who were sued by Patti Northcutt and her husband, Walter Northcutt (plaintiffs). Patti, a former employee and doctoral student at Auburn, alleged that the defendants retaliated against her for previous lawsuits and grievances she had filed, which were settled through agreements. She claimed that the defendants breached these settlement agreements and interfered with her ability to complete her doctoral program and obtain employment at Auburn.The plaintiffs initially filed their complaint in the Lee Circuit Court, which they amended multiple times. The third amended complaint included claims under the Family Medical Leave Act (FMLA), 42 U.S.C. § 1983 for First Amendment retaliation, equal protection, and procedural due process violations, as well as state-law claims for breach of contract, intentional interference with contractual relations, and intentional infliction of emotional distress. The defendants moved to dismiss these claims, asserting federal qualified immunity and State immunity under the Alabama Constitution.The Lee Circuit Court granted the motion to dismiss the First Amendment and intentional infliction of emotional distress claims but denied the motion regarding the other claims. The defendants then petitioned the Supreme Court of Alabama for a writ of mandamus to direct the trial court to dismiss the remaining claims.The Supreme Court of Alabama granted the petition in part, directing the trial court to dismiss the claims for monetary damages against the employee defendants in their individual capacities under § 1983 for equal protection and procedural due process violations, based on federal qualified immunity. The Court also directed the dismissal of the plaintiffs' request for attorneys' fees related to state-law claims for prospective injunctive relief, based on State immunity. However, the Court denied the petition regarding the plaintiffs' request for attorneys' fees related to federal-law claims for prospective injunctive relief and the state-law claims for monetary damages against the employee defendants in their individual capacities. View "Ex parte B.T. Roberts" on Justia Law

Faya Rose Toure sued the City of Selma, Chief of Police Spencer Collier, and police officer Devon McGuire following her arrest for fourth-degree theft of property and attempting to elude. Toure claimed McGuire and Collier committed assault and battery, false arrest, unlawful imprisonment, invasion of privacy, negligence, wantonness, abuse of legal process, unreasonable seizure, and defamation/libel. She also accused the City of negligent hiring, training, and supervision, and fostering a custom of police abuse. Toure sought $1,000,000 in compensatory damages and $3,000,000 in punitive damages.The defendants filed for summary judgment, citing peace-officer and State-agent immunity. They provided evidence including deposition testimonies, incident reports, and body camera footage showing McGuire witnessed Toure removing a campaign sign and subsequently attempting to elude him. Toure argued she removed the sign believing it was illegally placed and felt intimidated by McGuire, who was in an unmarked vehicle. The trial court granted summary judgment for the City but denied it for McGuire and Collier.The Supreme Court of Alabama reviewed the case. It found that McGuire and Collier were performing discretionary functions within their law enforcement duties, entitling them to immunity. The court determined that McGuire had at least arguable probable cause for Toure's arrest, and Toure failed to provide substantial evidence that McGuire or Collier acted willfully, maliciously, or beyond their authority. Consequently, the court held that McGuire and Collier were entitled to peace-officer and State-agent immunity and directed the trial court to enter summary judgment in their favor. The petition for a writ of mandamus was granted, and the writ was issued. View "Ex parte McGuire" on Justia Law

Spirit AeroSystems, a manufacturer of airplane parts, was issued a Request to Examine (RTE) by the Attorney General of Texas, W. Kenneth Paxton. The RTE statute allows the Attorney General to inspect business records without providing an opportunity for precompliance judicial review. Spirit challenged the statute as facially unconstitutional, arguing it violated the Fourth Amendment by not allowing precompliance review.The United States District Court for the Western District of Texas agreed with Spirit, finding the RTE statute unconstitutional for failing to provide precompliance review and issued a permanent injunction preventing the Attorney General from enforcing the RTEs against Spirit. The court's decision was based on the precedent set by City of Los Angeles v. Patel, which requires an opportunity for precompliance review to avoid Fourth Amendment violations.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Texas Supreme Court issued a decision in Paxton v. Annunciation House, Inc., which interpreted the RTE statute to include the required opportunity for precompliance review through Texas Rule of Civil Procedure 176.6. This rule allows recipients of administrative subpoenas to seek a protective order before compliance is required.Given the Texas Supreme Court's interpretation, the Fifth Circuit vacated the district court's judgment and remanded the case for further proceedings consistent with the new interpretation, which now provides the necessary precompliance review to satisfy Fourth Amendment requirements. View "Spirit Aerosystems v. Paxton" on Justia Law

Sacramento Television Stations Inc. (Sac TV) sought additional audio and video recordings from the City of Roseville (City) under the California Public Records Act (CPRA) related to an incident on April 6, 2023, where Roseville Police Department (Roseville PD) officers discharged firearms at a suspect, Eric J. Abril. The City provided limited footage, arguing that further disclosure would interfere with an active investigation. Sac TV filed a petition for writ of mandate to compel the City to release more recordings.The Superior Court of Placer County denied Sac TV's petition, finding that the City had shown by clear and convincing evidence that further disclosure would substantially interfere with an active investigation, specifically Abril's ongoing criminal case. The court acknowledged that more footage was required under CPRA but did not determine the extent due to the active investigation exemption.The California Court of Appeal, Third Appellate District, reviewed the case. The court concluded that the Superior Court's finding of an active investigation was not supported by substantial evidence. The court noted that a pending criminal prosecution alone does not constitute an active investigation under CPRA. The court also found that the City’s interpretation of the required disclosure was too narrow and that more context was needed to understand the incident involving the discharge of a firearm.The Court of Appeal vacated the Superior Court's ruling and directed it to hold further proceedings, including an in camera review of the City’s recordings, to determine the extent of additional disclosure required. The court emphasized the importance of providing sufficient context to fully understand the events captured in the recordings. The petition for rehearing was denied, and the judgment remained unchanged. View "Sacramento Television Stations Inc. v. Superior Ct." on Justia Law

In 2018, South Carolina excluded Planned Parenthood from its Medicaid program, citing state law prohibiting public funds for abortion. Planned Parenthood and patient Julie Edwards sued, claiming the exclusion violated the Medicaid any-qualified-provider provision, which allows Medicaid beneficiaries to obtain services from any qualified provider. Edwards preferred Planned Parenthood for gynecological care but needed Medicaid coverage. They filed a class action under 42 U.S.C. §1983 to enforce rights under the federal Medicaid statutes.The district court granted summary judgment for the plaintiffs and enjoined the exclusion. The Fourth Circuit affirmed. The Supreme Court granted certiorari, vacated, and remanded the case in light of Health and Hospital Corporation of Marion Cty. v. Talevski, which addressed whether another spending-power statute created §1983-enforceable rights. On remand, the Fourth Circuit reaffirmed its decision.The Supreme Court of the United States held that Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under §1983. The Court emphasized that spending-power statutes rarely create enforceable rights and that the any-qualified-provider provision lacks the clear rights-creating language necessary to support a §1983 action. The Court reversed the Fourth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Medina v. Planned Parenthood South Atlantic" on Justia Law