Justia Government & Administrative Law Opinion Summaries

Seven states challenged a rule by the Department of Education that modified an existing income contingent repayment (ICR) plan for federal student loans, known as the Saving on a Valuable Education (SAVE) plan. This plan altered payment thresholds, stopped interest accrual, and forgave loan balances after as little as ten years of repayment. The states argued that the Secretary of Education exceeded statutory authority by forgiving loans through an ICR plan.The United States District Court for the Eastern District of Missouri found that the states were likely to succeed on their claim and issued a preliminary injunction against the rule’s early loan forgiveness provisions. Both parties appealed: the federal officials sought to vacate the preliminary injunction, while the states requested a broader injunction.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the states were likely to succeed in their claim that the Secretary’s authority to promulgate ICR plans does not include loan forgiveness at the end of the payment period. The court held that the statute requires ICR plans to be designed for borrowers to repay their loan balances in full through payments that can fluctuate based on income during the payment term. The court determined that the Secretary had exceeded this authority by designing a plan where loans are largely forgiven rather than repaid.The Eighth Circuit affirmed the entry of the preliminary injunction but concluded that the district court erred by not enjoining the entire rule. The court remanded the case with instructions to modify the injunction to cover the entire SAVE Rule and the revived forgiveness provisions under the previous REPAYE plan. View "State of Missouri v. Trump" on Justia Law

The plaintiff, the register of deeds for Norfolk County, filed a lawsuit against the county commissioners for Norfolk County, seeking declaratory, mandamus, and injunctive relief regarding funding and personnel matters within the registry of deeds. The dispute centered on hiring a new chief information officer and the funding for that position. While this litigation was ongoing, the plaintiff requested the county director to transfer funds within the registry's budget to cover legal fees for the personnel litigation. The county director denied these requests, prompting the plaintiff to file a second lawsuit for declaratory, mandamus, and injunctive relief.In the Superior Court, the plaintiff moved for summary judgment regarding the budget transfers, and the defendants cross-moved for summary judgment. The judge granted summary judgment in favor of the plaintiff, ruling that under G. L. c. 35, § 32, the plaintiff had the authority to transfer funds within a main group of the budget based on his opinion of public necessity and convenience. The defendants appealed this decision.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Superior Court's decision. The court held that the statutory language of G. L. c. 35, § 32, clearly grants the authorized official the discretion to transfer funds within a main group based on their opinion of public necessity and convenience. The court found that the plaintiff's opinion was sufficient justification for the transfers and that the defendants' interference was unlawful. The court ordered that any outstanding amounts that should have been transferred be specifically authorized by the defendants and that the defendants refrain from hindering lawful transfers within the Contractual Services main group in the future. View "Register of Deeds for Norfolk County v. County Director for Norfolk County" on Justia Law

The case involves Tarlochan Sandhu, who worked for various public agencies as a finance and accounting professional and was a member of CalPERS, receiving retirement benefits upon his retirement in 2011. After retiring, Sandhu was hired by Regional Government Services (RGS) in 2015, which assigned him to work for several cities. RGS considered Sandhu its employee, providing him with benefits and paying him, while the cities paid RGS for his services. CalPERS determined Sandhu was a common law employee of the cities, violating postretirement employment rules, and the trial court upheld this determination.The Superior Court of Sacramento County reviewed the case, where Sandhu challenged CalPERS’s decision, arguing he was not a common law employee and that the decision was based on underground regulations. The trial court applied its independent judgment, finding the evidence supported CalPERS’s determination that Sandhu was a common law employee of the cities. The court found the cities had the right to control Sandhu’s work, which is the principal test for an employment relationship, and that several secondary factors also supported this conclusion.The California Court of Appeal, Third Appellate District, reviewed the case. The court affirmed the trial court’s judgment, holding that the common law test for employment applies and that substantial evidence supported the trial court’s finding that Sandhu was a common law employee of the cities. The court also found that Sandhu forfeited his argument regarding underground regulations by not properly raising it in the trial court. The judgment was affirmed, and the parties were ordered to bear their own costs on appeal. View "Sandhu v. Bd. of Admin. of CalPERS" on Justia Law

A resident of Alaska filed a lawsuit challenging amendments to the State’s predator control program. The resident claimed that after the changes were implemented, she observed a noticeable decrease in the brown bear population at Katmai National Park, where she frequently visited to view bears. She argued that the Board of Game violated its constitutional and statutory duties by not providing adequate notice and opportunities for public input before adopting the changes, which expanded the program to target bears.The Superior Court of Alaska, Third Judicial District, dismissed the complaint, concluding that the resident lacked standing and was not entitled to a declaratory judgment on the validity of the regulatory change. The court also awarded attorney’s fees to the Board of Game and the Commissioner of the Department of Fish & Game.The Supreme Court of the State of Alaska reviewed the case and held that the resident had standing because she demonstrated an injury to her interest in viewing bears at Katmai National Park, which was sufficient to show standing. The court also concluded that she was entitled to a declaratory judgment on the validity of the regulation. The Supreme Court reversed the dismissal of her complaint, vacated the associated award of attorney’s fees, and remanded the case for further proceedings. View "Bittner v. State of Alaska" on Justia Law

An assistant public defender resigned unexpectedly, leading the Public Defender Agency to propose a temporary reassignment plan for her cases until a permanent replacement could be hired. The superior court rejected this plan, as it did not assign specific attorneys to the cases. The court ordered the Agency to inform affected clients that they would need to waive their rights to effective assistance of counsel until a permanent attorney was assigned, or the Agency would withdraw. The Agency managed to assign specific attorneys to all but one case, from which it withdrew as ordered. The court then appointed the Office of Public Advocacy (OPA) to represent that client. OPA moved to withdraw, arguing that its appointment was unauthorized under AS 44.21.410 and that the superior court exceeded its authority. The superior court denied the motion, leading OPA to file an original application for relief with the court of appeals, which certified the application to the Alaska Supreme Court.The Alaska Supreme Court reviewed the case and held that the superior court did not err by intervening in the affected cases. The court determined that the Agency's lack of capacity to provide effective representation constituted a conflict of interest under the Rules of Professional Conduct and the state and federal constitutions. The court concluded that when the Agency has a conflict due to lack of capacity, AS 44.21.410(a)(4) requires that OPA be assigned to represent the affected clients. The Supreme Court affirmed the superior court's order appointing OPA to represent the client, explaining that the superior court had a duty to ensure the client's right to effective assistance of counsel and that a lack of capacity can amount to a conflict of interest requiring OPA's appointment. View "Office of Public Advocacy v. Superior Court, First Judicial District" on Justia Law

Waukegan Potawatomi Casino, LLC (WPC) alleged that its Fourteenth Amendment rights were violated when the City of Waukegan did not advance its casino proposal for licensing consideration. WPC claimed it experienced intentional discrimination during the application process as a "class of one." The City of Waukegan certified three other applicants but not WPC, which alleged that the process was rigged to benefit another applicant, Lakeside Casino, LLC. WPC pointed to the relationship between the City's mayor and a founding partner of Lakeside, as well as the City's handling of supplemental information from applicants, as evidence of discrimination.The United States District Court for the Northern District of Illinois granted summary judgment for the City. The court concluded that WPC, as an arm of a sovereign Native American tribe, could not maintain a claim under 42 U.S.C. § 1983. Additionally, the court found that WPC's class-of-one equal protection claim failed because WPC was not similarly situated to the other applicants and there were multiple conceivable rational bases for the City's conduct.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that WPC could not carry its heavy burden as a class-of-one plaintiff. The court noted that there were several rational bases for the City's decision, including differences in the casino proposals and the applicants' experience. The court also found that WPC failed to identify a similarly situated comparator who was treated more favorably. The court concluded that the City's conduct throughout the review process, including its handling of supplemental information, had rational justifications. Thus, WPC's class-of-one claim failed under both prongs of the analysis. View "Waukegan Potawatomi Casino, LLC v City of Waukegan" on Justia Law

In 2019, Colby James Bray died while in the custody of the Idaho Department of Juvenile Corrections (IDJC). His parents, Jeffrey and Michelle Bray, acting as personal representatives of his estate, filed a wrongful death suit in federal court one day before the two-year statute of limitations expired. They later voluntarily dismissed the federal case and refiled in state court nearly three years after Colby's death. The defendants moved for summary judgment, arguing the claims were time-barred by the two-year statute of limitations. The district court granted the motions and dismissed the complaint with prejudice.The Brays appealed, arguing that Idaho Code section 5-234 and 28 U.S.C. section 1367(d) tolled the statute of limitations. The district court had concluded that section 5-234 did not toll the time for filing the state complaint and that section 1367(d) did not apply to IDJC due to Eleventh Amendment immunity. The court also awarded costs and attorney fees to the defendants.The Supreme Court of Idaho affirmed the district court's ruling that section 5-234 did not toll the statute of limitations. It also agreed that the claims against Meacham and the Individual Defendants were time-barred under section 1367(d) because the Brays did not file within 30 days after the federal court dismissed those claims. However, the court found that section 1367(d) did toll the time for filing the complaint against IDJC, but IDJC was immune from the claims under Idaho Code section 6-904B(5). The court upheld the district court's award of attorney fees and costs to the defendants and awarded attorney fees and costs on appeal to the respondents. View "Bray v. ID Dept of Juvenile Corrections" on Justia Law

M.R., a minor, was substantiated by the Department of Children and Families (DCF) for sexual abuse of another minor. DCF sent the notice of substantiation to M.R.'s father, who requested an administrative review but did not participate in it. The review upheld the substantiation, and M.R.'s father did not appeal further. M.R. later sought a second review from the Human Services Board after the appeal period had expired, claiming he was unaware of the substantiation and the review. The Board dismissed his appeal as untimely.The Human Services Board found that M.R.'s appeal was not filed within the required 30-day period after the administrative review decision. M.R. argued that he was entitled to personal notice under the statute, that the lack of direct notice deprived him of due process, and that there was good cause for his delay in filing the appeal. The Board rejected these arguments and dismissed the appeal.The Vermont Supreme Court reviewed the case and affirmed the Board's decision. The Court held that the statutory requirement to send notice to the minor's parents or guardian was sufficient and did not violate due process. The Court found that the procedures in place were reasonably calculated to apprise the minor and their parents of the substantiation decision and their rights to request reviews. The Court also held that there was no good cause for M.R.'s untimely appeal, as the failure to appeal was due to factors within his father's control. Therefore, the Board's dismissal of the appeal as untimely was upheld. View "In re Appeal of M.R." on Justia Law

The case involves the interpretation of the phrase “has proven to be operational” in the definition of “best available control technology” (BACT) under Texas law. The Texas Commission on Environmental Quality (TCEQ) is responsible for issuing permits for facilities like power plants, ensuring they use BACT, which must be technically practicable and economically reasonable. The dispute centers on whether BACT requires a pollution control method to be currently operating under a TCEQ permit or if it can refer to methods deemed capable of operating in the future.The United States Court of Appeals for the Fifth Circuit certified this question to the Supreme Court of Texas. The underlying litigation about the permitting of a power plant is not pending in the Texas Supreme Court, but the court has jurisdiction to answer the certified question under the Texas Constitution.The Supreme Court of Texas held that the phrase “has proven to be operational” requires that the pollution control method must have already been demonstrated to be operational through experience and research. It does not require the method to be currently operating under a TCEQ permit, nor does it allow for methods that are only deemed capable of operating in the future. The court emphasized that the statutory requirement for BACT includes considerations of technical practicability and economic reasonableness, and the administrative rule must be interpreted based on its plain text. The court rejected the notion that previously issued permits determine BACT for other facilities, stating that each facility’s proposal must be evaluated on its own merits based on real-world experience and research. View "PORT ARTHUR COMMUNITY ACTION NETWORK v. TEXAS COMMISSION ON ENVIRONMENTAL QUALITY" on Justia Law

A vacancy on the Scott County Board of Supervisors occurred when Tony Knobbe resigned to become the Scott County Treasurer. A committee of county officials decided to fill the vacancy by appointment and kept certain applications confidential during the process. The committee referred to applicants by numbers and only revealed the name of the appointed individual. After the appointment, two individuals submitted open records requests for the confidential names and applications, which Scott County denied, citing Iowa Code section 22.7(18).The individuals filed a petition in the Iowa District Court for Scott County, which granted summary judgment in favor of Scott County, determining that the applications were exempt from disclosure under Iowa Code section 22.7(18). The district court relied on the precedent set in City of Sioux City v. Greater Sioux City Press Club, which held that employment applications could be kept confidential.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that the applications for the vacant county board of supervisors position were not confidential under section 22.7(18). The court reasoned that the applicants were not promised confidentiality beforehand, and the public nature of the appointment process meant it was not reasonable to believe that people would be deterred from applying if their applications were disclosed. The court ordered that the names and applications be disclosed and awarded costs and reasonable attorney fees to the plaintiffs. The case was remanded for further proceedings. View "Diercks v. Scott County, Iowa" on Justia Law