Justia Government & Administrative Law Opinion Summaries

A group of neighbors opposed the development of a public sports park on a 65-acre parcel in Maui. The State Department of Land and Natural Resources (DLNR) sought and received a special use permit from the County of Maui Planning Commission to build the park. Several future members of the neighbors’ group, Maui Lani Neighbors, Inc. (MLN), received notice of the permit hearing, attended, and some testified, but none formally intervened in the proceedings. After the permit was granted, one future MLN member filed an administrative appeal but later dismissed it. MLN was then incorporated and filed a lawsuit in the Circuit Court of the Second Circuit, challenging the permit on zoning, environmental, constitutional, and procedural grounds.The Circuit Court of the Second Circuit dismissed most of MLN’s claims, holding that they should have been brought as an administrative appeal of the Planning Commission’s decision under Hawai‘i Revised Statutes (HRS) § 91-14, and that MLN failed to exhaust administrative remedies. The Intermediate Court of Appeals (ICA) affirmed, but with different reasoning on some points. The ICA held that the administrative process provided an exclusive remedy for most claims, but allowed that some environmental claims under HRS chapter 343 (the Hawai‘i Environmental Policy Act, or HEPA) could proceed in circuit court if they did not seek to invalidate the permit.The Supreme Court of Hawai‘i affirmed the ICA’s judgment in most respects, but clarified that MLN’s claims under HRS chapter 343 were not subject to the exhaustion doctrine and could be brought directly in circuit court. The court held that, except for HEPA claims, MLN was required to challenge the permit through an administrative appeal, and that the declaratory judgment statute (HRS § 632-1) did not provide an alternative route. The court remanded the case to the circuit court to consider the HEPA-based claims. View "Maui Lani Neighbors v. State" on Justia Law

Several individuals who had received grants of parole under programs established by the Department of Homeland Security (DHS) for nationals of Cuba, Haiti, Nicaragua, and Venezuela challenged the government’s decision to terminate those grants. The parole programs, created during the Biden Administration, allowed eligible individuals from these countries to enter the United States temporarily for up to two years, based on urgent humanitarian reasons or significant public benefit. When President Trump took office in January 2025, he issued executive orders directing DHS to end categorical parole programs, including the CHNV programs. DHS subsequently published a notice terminating the programs and revoking all existing grants of parole within thirty days, rather than allowing them to expire naturally.The plaintiffs, affected by the early termination, filed suit in the United States District Court for the District of Massachusetts. The district court certified a class of affected individuals and granted a preliminary stay, preventing DHS from revoking their parole grants before the original expiration dates. The court found that the plaintiffs were likely to succeed on their claim that the categorical termination was arbitrary and capricious under the Administrative Procedure Act (APA), in part because the agency’s rationale rested on a legal error and failed to adequately consider reliance and humanitarian interests.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s order. The First Circuit held that the relevant statute requires DHS to grant parole only on a case-by-case basis, but does not impose the same limitation on the termination of parole. The court also found that the agency’s explanation for terminating the parole programs was not so deficient as to be arbitrary and capricious under the APA. Concluding that the plaintiffs had not made a strong showing of likelihood of success on the merits, the First Circuit vacated the district court’s stay and remanded for further proceedings. View "Doe v. Noem" on Justia Law

Several individuals and a firearms instruction company challenged various aspects of New York’s Concealed Carry Improvement Act (CCIA) and the way the Suffolk County Police Department (SCPD) implements the law. The individual plaintiffs, all Suffolk County residents, objected to requirements for obtaining a handgun license, including a “good moral character” standard, an in-person interview, disclosure of household members and character references, a list of social media accounts, and completion of eighteen hours of firearms training. They also alleged that the SCPD’s process for scheduling interviews and issuing licenses could take years, far exceeding statutory timelines. Additionally, the plaintiffs, including firearms instructors, challenged an alleged SCPD policy of arresting unlicensed individuals participating in live-fire training, despite a state law exemption for such training.The United States District Court for the Eastern District of New York denied the plaintiffs’ motion for a preliminary injunction. The court found that the individual applicants lacked standing to challenge the CCIA’s requirements because they had not completed the application process, and that none of the plaintiffs had standing to challenge the SCPD’s arrest policy due to a lack of credible threat of enforcement. The district court did not address the challenge to the SCPD’s processing delays.The United States Court of Appeals for the Second Circuit held that the applicants did have standing to challenge the CCIA’s requirements and the SCPD’s processing delays, but affirmed the denial of a preliminary injunction because the plaintiffs were unlikely to succeed on the merits of their facial Second Amendment challenges, except for the social media disclosure requirement, which was already preliminarily enjoined in another case, rendering that issue moot. The court also found that at least one plaintiff had standing to challenge the SCPD’s arrest policy and vacated the district court’s ruling on that issue, remanding for further proceedings. The disposition was affirmed in part, vacated in part, and remanded. View "Giambalvo v. Suffolk Cnty." on Justia Law

Central Vermont Medical Center (CVMC) submitted its proposed budget for fiscal year 2025, seeking an 11.9% increase in net patient service revenue (NPR) and a 5.5% increase in commercial rates, both of which exceeded the benchmarks set by the Green Mountain Care Board. The Board’s benchmarks, established in its annual guidance, were 3.5% for NPR growth and 3.4% for commercial rate growth. The Board required hospitals exceeding these benchmarks to provide credible justification, such as evidence of improved access or quality of care. CVMC’s submission was reviewed through hearings and public comment, during which the Board found that CVMC’s justifications were insufficient, particularly regarding efficiency, productivity, and cost containment.The Green Mountain Care Board, after considering the evidence and statutory obligations, modified CVMC’s budget, allowing a 6% NPR growth and a 3.4% commercial rate increase. The Board found that CVMC could achieve financial sustainability through cost reductions and improved productivity rather than higher price increases. The Board imposed specific terms and conditions on the budget, emphasizing the need for efficient operations and balancing financial needs with statewide health care affordability and access.On appeal, the Vermont Supreme Court reviewed the Board’s decision under a deferential standard, presuming the Board’s actions valid unless shown otherwise by clear and convincing evidence. The Court rejected CVMC’s arguments that the Board acted with unfettered discretion, violated procedural due process, or was required to regulate on a per-capita basis. The Court found that the Board’s process was guided by statutory standards, rules, and annual guidance, and that CVMC had adequate notice and opportunity to participate. The Supreme Court of Vermont affirmed the Board’s decision. View "In re Central Vermont Medical Center Fiscal Year 2025" on Justia Law

An individual pleaded guilty to multiple sexual offenses committed against two girls, aged thirteen and fourteen, when he was eighteen years old. The offenses included several instances of rape and indecent assault. The individual had a history of psychological diagnoses, including autism spectrum disorder. After his conviction, the Sex Offender Registry Board (SORB) initially classified him as a level three sex offender, which would require the highest level of public notification. The individual challenged this classification, leading to a de novo hearing before a SORB hearing examiner.At the hearing, the examiner found by clear and convincing evidence that the individual posed a moderate risk of reoffense and a moderate degree of danger, resulting in a reclassification to level two. The examiner considered several statutory and regulatory factors, including the number of victims, the nature and location of the offenses, and the individual’s psychological profile. The examiner also considered the fact that the individual committed multiple offenses, including repeated offenses against one victim, as relevant to the degree of dangerousness. The examiner determined that Internet publication of the individual’s registration information would serve a public safety interest. The individual sought judicial review in the Massachusetts Superior Court, which affirmed the SORB’s decision.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the SORB hearing examiner did not err in considering the individual’s multiple offenses as relevant to dangerousness under regulatory factor thirty-seven, even though such consideration is limited under factor two, which addresses risk of reoffense. The court also declined to find the application of factor thirty-seven unconstitutional due to a lack of empirical evidence, given the statutory mandate to consider the number of offenses. The court affirmed the classification as a level two offender and the requirement for Internet dissemination of registration information. View "Doe v. Sex Offender Registry Board" on Justia Law

A school resource officer employed by the Lee County School District was fatally injured while directing traffic on a state highway when a speeding motorist struck his parked vehicle, causing it to hit him. At the time, a warning sign intended to alert drivers to the school zone was allegedly inoperable. The officer’s wife received workers’ compensation benefits from his employer, but his two adult sons did not. The sons filed a wrongful death lawsuit against the Mississippi Department of Transportation (MDOT), alleging negligence in maintaining the warning sign and failing to warn of a dangerous condition.The case was heard in the Lee County Circuit Court. MDOT moved for summary judgment, arguing it was immune from suit under Mississippi Code Section 11-46-9(1)(l) because the decedent was a governmental employee whose injury was covered by workers’ compensation. The sons opposed, contending the statute did not bar their claims as wrongful death beneficiaries and, if it did, that the statute was unconstitutional. The trial court granted summary judgment to MDOT, finding the statute applied and provided immunity, and also upheld the statute’s constitutionality.On appeal, the Supreme Court of Mississippi reviewed the statutory interpretation and constitutional challenge de novo. The court held that wrongful death beneficiaries stand in the position of the decedent, and because the decedent could not have sued MDOT due to statutory immunity, neither could his sons. The court further held that Section 11-46-9(1)(l) does not violate the Mississippi Constitution’s remedy clause or the Equal Protection Clause of the U.S. Constitution, as the statute is rationally related to the legitimate purpose of protecting public funds. The Supreme Court of Mississippi affirmed the trial court’s orders granting summary judgment and upholding the statute’s constitutionality. View "Patterson v. State of Mississippi, ex rel. Attorney General Fitch" on Justia Law

A group of plaintiffs from Kauaʻi, Oʻahu, and Maui challenged a series of emergency proclamations issued by the Governor of Hawaiʻi, beginning in July 2023, which declared affordable housing a state emergency. These proclamations suspended various state laws and established expedited processes for approving and constructing housing projects, including the creation of a State Lead Housing Officer and a Build Beyond Barriers Working Group. The initial proclamations allowed all housing projects, not just affordable housing, to benefit from the suspended laws and expedited certification. Over time, the proclamations were revised, narrowing their scope and transferring certification authority to the Hawaiʻi Housing Finance and Development Corporation (HHFDC).The plaintiffs first filed a writ of quo warranto against the State Lead Housing Officer and the Working Group, arguing that the proclamations exceeded the governor’s statutory authority and violated constitutional provisions. The Circuit Court of the Second Circuit dismissed the petition without prejudice, finding the mechanism inapplicable and the claims moot, but allowed amendment. Plaintiffs then filed an amended complaint for declaratory relief against the governor and HHFDC, which was also dismissed for lack of standing and procedural defects. Plaintiffs appealed, and after briefing in the Intermediate Court of Appeals, the case was transferred to the Supreme Court of Hawaiʻi.The Supreme Court of Hawaiʻi held that the case was justiciable, plaintiffs had standing based on their constitutional right to a clean and healthful environment, and procedural missteps did not bar their claims. The court articulated a standard for reviewing emergency proclamations: they must be rationally related to public health, safety, and welfare, and the executive actions must be reasonably necessary to address the emergency. Applying this, the court found the Sixth through Fifteenth proclamations valid, but held the first five exceeded the governor’s emergency powers. The court vacated the circuit court’s dismissal of the declaratory judgment claims. View "Nakoa v. Governor of the State of Hawai'i" on Justia Law

A charter city in California was required by state law to update its housing element—a component of its general plan addressing housing needs—by October 15, 2021. The city submitted a draft housing element to the California Department of Housing and Community Development (HCD), which found the draft would comply with state law if adopted. However, the city refused to adopt the revised housing element, citing concerns about environmental impacts and the number of affordable housing units required. The city also filed a federal lawsuit challenging the constitutionality of the Housing Element Law, which was ultimately dismissed for lack of standing.The People of California, represented by the Attorney General and the HCD, filed a petition for writ of mandate in the Orange County Superior Court, later transferred to the San Diego County Superior Court, seeking to compel the city to adopt a compliant housing element. The Kennedy Commission, an affordable housing advocacy group, intervened. The trial court granted the State’s petition for writ of mandate, finding the city had a ministerial duty to adopt a compliant housing element, but the court’s order did not include a 120-day compliance deadline or provisional remedies limiting the city’s permitting and zoning authority, as requested by the State. The court also stayed further proceedings due to pending appeals and unresolved cross-petitions.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that Article 14 of Chapter 3 of Division 1 of Title 7 of the Government Code, which includes the 120-day compliance deadline and provisional remedies, applies to enforcement actions against charter cities. The court directed the trial court to vacate its prior order and issue a new order including the required compliance deadline and provisional remedies, and to lift its stay and expeditiously resolve remaining issues. The court declined to order entry of final judgment while other pleadings remained unresolved. View "Kennedy Commission v. Superior. Ct." on Justia Law

In March 2025, the President issued an executive order directing federal officials to eliminate non-statutory functions and reduce statutory functions of three federal agencies: the Institute of Museum and Library Services (IMLS), the Minority Business Development Agency (MBDA), and the Federal Mediation and Conciliation Service (FMCS). These agencies, established and funded by Congress, provide grants and services to states and other entities. Following the executive order, the agencies terminated, reassigned, or placed on leave nearly all employees and canceled numerous grants, which plaintiffs—twenty-one states—alleged caused immediate and ongoing harm, including loss of services, forced layoffs, and canceled programming.The United States District Court for the District of Rhode Island granted a preliminary injunction, finding that the plaintiffs had suffered and would continue to suffer concrete injuries due to the agencies’ actions. The court determined that the agencies’ actions likely violated the Administrative Procedure Act and constitutional provisions, including the Take Care Clause and separation of powers. The injunction barred implementation of the executive order as to the three agencies, required reversal of actions taken to implement the order, restoration of employees, and resumption of grant funding, while allowing for efficiency measures not motivated by the executive order. The district court denied the government’s request for a stay of the injunction pending appeal.The United States Court of Appeals for the First Circuit reviewed only the government’s motion for a stay pending appeal. The court denied the stay, holding that the government failed to make a strong showing of likely success on the merits, particularly because it did not adequately challenge the district court’s constitutional analysis and had not preserved certain arguments. The court also found that the balance of harms and public interest did not favor a stay. View "Rhode Island v. Trump" on Justia Law

Rockwood Auto Parts, Inc. and Rockwood Towing, Inc., along with their owner, Jacques Poli, had longstanding business relationships with the Monroe County Sheriff’s Office, performing vehicle maintenance and towing services. After Troy Goodnough was elected sheriff in 2020, Monroe County initiated a competitive bidding process for fleet maintenance, ultimately awarding the contract to Gerweck Nissan instead of Rockwood Auto. Goodnough also revised the county’s towing rotation, reducing Rockwood Towing’s share of business. Additionally, Goodnough and Sergeant Michael Preadmore conducted warrantless audits of Rockwood’s premises and Poli’s property to inventory county assets, which led to a state police investigation but no criminal charges.The plaintiffs filed suit in the United States District Court for the Eastern District of Michigan, alleging violations of their Fourth Amendment rights due to the warrantless searches, and asserting equal protection and due process claims under the Fourteenth Amendment related to the loss of contracts and towing business. They also sought to impose municipal liability on Monroe County. The district court granted summary judgment to the defendants on all claims, finding no genuine disputes of material fact and concluding that the searches were consensual, the contract decisions had rational bases, and no protected property interest existed in the bidding process.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment de novo. The Sixth Circuit affirmed the district court’s judgment, holding that the searches were conducted with valid consent, the changes to contracts and towing lists were supported by rational bases and did not constitute unconstitutional discrimination, and the plaintiffs lacked a protected property interest in the fleet-maintenance contract. The court also found no basis for municipal liability under Monell, as no underlying constitutional violation was established. View "Rockwood Auto Parts, Inc. v. Monroe County" on Justia Law