Justia Government & Administrative Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Defendant's petition and amended petition for declaratory judgment and writ of mandamus wherein Defendant alleged that the Arkansas Department of Correction illegally changed his discharge date, holding that the circuit court correctly denied the petition and amended petition.After being sentenced in 2007, Defendant was paroled in 2015. Defendant was taken into custody a year later. In his petition and amended petition Defendant alleged that after revocation of his parole and his return to prison, he was informed that his discharge date had been illegally moved. The circuit court denied the petition for failure to state a claim for relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied Defendant's petitions for declaratory judgment and writ of mandamus. View "Andrews v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Robyn Young's motion to dismiss this action brought by Granite School District regarding settlement proceeds Young had received for industrial injuries, holding that the Labor Commission had exclusive jurisdiction over the factual questions at the heart of this reimbursement dispute.Young, a special education teacher, sought workers' compensation for injuries she received at the hands of her students. An administrative law judge awarded Young benefits, finding that Young was permanently and totally disabled and that Young did not have to reimburse Granite with funds she received from a legal settlement she had obtained against medical debt collectors for violations of the Fair Debt Collection Practices Act. Granite then initiated suit for reimbursement from Young under the Utah Workers' Compensation Act. The district court granted Young's motion to dismiss. The Supreme Court affirmed, holding that the district court did not err when it dismissed Granite's complaint because the Workers' Compensation Act assigned the Commission exclusive jurisdiction over this dispute. View "Granite School District v. Young" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Workers' Compensation Board determining that Richard Lane's notice to his former employer, Tennco Energy, Inc., that he was asserting a subsequent claim against it was timely, holding that there was no error.In 2019, Lane filed a coal workers' pneumoconiosis (CWP) claim against Tennco Energy, Inc. An administrative law judge dismissed the claim after determining that Lane had failed to give timely notice of the claim pursuant to Ky. Rev. Stat. 341.316(2). The Board reversed, concluding that a prior CWP claim that Lane had previously settled against a former employer had no bearing on Lane's duty to notice Tennco when he asserted a subsequent claim against it. The Supreme Court affirmed, holding that remand was required for additional findings of fact under this opinion. View "Tennco Energy, Inc. v. Lane" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the ruling of the Workers' Compensation Board affirming the denial of Francisco Rodarte's motion to reopen and reversing the ruling that Rodarte's shoulder claim was barred due to failure to join, holding that the court of appeals did not err.Rodarte sustained two work-related injuries while working for BlueLinx Corporation - a knee and ankle injury in 2016 and a shoulder injury in 2018. In Rodarte and BlueLinx ultimately entered into a settlement agreement for Rodarte's knee and ankle injuries. BlueLinx denied Rodarte's shoulder claim, however, concluding it was barred pursuant to Ky. Rev. Stat. 342.270 due to Rodarte's failure to join it to the 2016 claim. Rodarte moved to reopen the 2016 claim, which the chief administrative law judge denied. Thereafter, an administrative law judge dismissed the shoulder claim. The Board affirmed the denial of the motion to reopen and reversed the dismissal of the shoulder claim. The court of appeals affirmed the Board's ruling on the motion to reopen but reversed its determination that Rodarte's shoulder claim was not barred for failure to join. The Supreme Court affirmed, holding that the court of appeals did not err in its rulings. View "Rodarte v. Bluelinx Corp." on Justia Law

The Pennsylvania Supreme Court considered a class action challenge to the constitutionality of Act 12 of 2019 (“Act 12”),3 which, inter alia, enacted changes to the Pennsylvania Human Services Code. In particular, the Court had to determine whether the lawmaking which culminated in the passing of Act 12 satisfied the state Constitution's Article III requirements. The Court held that the process by which the General Assembly passed Act 12 satisfied both the “original purpose” and “single subject” mandates found in Article III of the Pennsylvania Constitution. Thus, the Court affirmed the order of the Commonwealth Court and found the statutory enactment to be constitutional. View "Weeks, et al. v. Dept. Health Serv." on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus ordering Respondents to provide records responsive to request numbers 2, 3, and 4 from Jeffrey Howard's August 2022 public records request and denied the writ as to the remaining public records requests, holding that Howard was entitled to mandamus in part.Howard, an inmate, brought this action seeking a writ of mandamus to produce records and documents in response to several records requests. Howard sought an award of statutory damages as to each request. The Supreme Court (1) granted the writ ordering Respondents to provide records responsive to three public records requests; and (2) denied the writ as to the remaining requests because Howard no longer sought mandamus relief as to those public records requests. View "State ex rel. Howard v. Watson" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals granting summary judgment on Plaintiff's claim under the Open Meetings Act, Ohio Rev. Code 121.22 and denying Plaintiff's request for an award of statutory damages under the Public Records Act, Ohio Rev. Code 149.43(C)(2), holding that the court of appeals erred in its analysis of the statutory damages issue.In an earlier appeal, the Supreme Court reversed the court of appeals' grant of summary judgment for the Portage County Board of Commissioners, the Portage County Solid Waste Management District Board of Commissioners (SWMD) and the Portage County Court of Common Pleas and remanded the case with instructions that the court of appeals to determine whether Plaintiff was entitled to relief under the Open Meetings Act and Public Records Act. The court of appeals granted summary judgment for the board and the SWMD and denied statutory damages. The Supreme Court remanded the matter, holding that Plaintiff was entitled to an award of statutory damages. View "State ex rel. Ames v. Portage County Bd. of Commissioners" on Justia Law

In 2019, two Oakland journalists filed requests with the Oakland Police Department under the California Public Records Act (CPRA) (previously Gov. Code 6250, now 7921.000), including for information regarding the “Celeste Guap” scandal, which involved several Oakland police officers who had sex with Guap while she was underage. The trial court ordered Oakland to produce documents responsive to those requests. Oakland produced a redacted version of the internal affairs investigation report.The court of appeal agreed that some of the challenged redactions were not permitted under the statute. In 2018 Senate Bill 1421 amended Penal Code section 832.7 to require public access to certain records of police misconduct and use of force. The trial court improperly permitted Oakland to redact certain information under section 832.7(b)(4) and (b)(5), including the Guap report’s training and policy recommendations; witness statements containing general information about Guap and her social-media use (without any information about allegations of misconduct against any officer); screenshots of Guap’s Facebook profile; and large portions of her statements to investigators. Redaction of witness-officer’s names or other identifying information from the interview summaries is not appropriate under section 832.7(b)(6)(B) in order to “preserve the anonymity of . . . witnesses.” View "Bondgraham v. Superior Court of Alameda County" on Justia Law

The Supreme Court affirmed the judgment of the trial court in favor of Reagan Outdoor Advertising in this appeal from the determination that Reagan's billboard had lost its legal nonconforming status, holding that the trial court correctly entered judgment for Reagan.An ordinance of the city of Noblesville bans pole signs, which are signs affixed to poles or other uprights installed in the ground. Reagan, whose billboards the city classifies as pole signs, was allowed signs to remain that pre-dated the ordinance if they were kept in good repair and not relocated. When Reagan repaired damage to one of the billboard's support posts the city issued a stop-work order before Reagan could reattach the sign's display, concluding that Reagan had relocated the sign, which therefore lost its legal nonconforming status. The zoning board of appeals affirmed, but the trial court reversed. The Supreme Court affirmed, holding that the ordinance's use of the word "relocate" was ambiguous and, consistent with this Court's interpretative canons, must be resolved in Reagan's favor. View "Noblesville Indiana Board of Zoning Appeals v. FMG Indianapolis, LLC" on Justia Law

The 2019 Illinois Cannabis Regulation Act legalized the recreational use of cannabis and established a licensing system for cannabis dispensaries. Applications for the first licenses closed in 2020; by mid-2021 the Department had allocated 185 licenses using a lottery procedure. The issuance of licenses was stayed during state-court litigation. For a second group of licenses in 2022, the Department established a point system that heavily favored longtime Illinois residents. The plaintiffs want to invest in Illinois cannabis dispensaries but neither lived in Illinois.In March 2022, they filed suit raising a dormant Commerce Clause challenge to the residency provisions and sought a preliminary injunction halting the completion of the allocated 2021 licenses and enjoining the ongoing process for 2022 licenses. The district court denied the motion. The Seventh Circuit affirmed. The denial of a preliminary injunction allowed the Department to issue the 2021 licenses; it did so, largely mooting the appeal. To the extent that unwinding the licenses remains possible, the judge weighed the equities and held that the plaintiffs waited too long to challenge the residency provisions; an injunction would severely harm reliance interests and disrupt the orderly completion of the first-round licensing process. At the time of the ruling, the Department had not finalized the criteria for the second group but a challenge was unripe because the Department might materially modify the criteria. The Department subsequently finalized the 2022 rules and deleted provisions favoring Illinois residents. View "Finch v. Treto" on Justia Law