Justia Government & Administrative Law Opinion Summaries

The Supreme Court held that the payment of a civil fine for a traffic violation under a city's automated traffic enforcement program without a dispute of liability for the violation precludes those improperly ticketed under the program from raising an unjust enrichment claim against the city in a separate action.Appellees - Plaintiffs in a class action - were vehicle lessees who received tickets under the city of the city of Cleveland's automated traffic enforcement program. Plaintiffs did not appeal their cases, and most paid the civil fine. The trial court granted Appellees' motion for class certification. The City appealed, arguing that res judicata precluded class relief. After the court of appeals affirmed the class certification order the trial court ruled in favor of the class. The Supreme Court reversed, holding that by paying their civil fines and not disputing their liability, Appellees admitted their liability for their traffic violations, and res judicata prevented a subsequent lawsuit. View "Lycan v. City of Cleveland" on Justia Law

The First Circuit denied Petitioner's petition for review of the decision of the Board of Immigration Appeals (BIA) dismissing Petitioner's appeal of an order of removal from the Immigration Judge (IJ), holding that Petitioner was not entitled to relief.Petitioner, who was born in Jamaica, conceded that, unless he was a citizen of the United States through derivative citizenship, he was removable as an alien who had been convicted of an aggravated felony. Petitioner accepted an order of removal from the IJ and waived appeal to the BIA. Thereafter, Petitioner filed a pro se appeal claiming derivative United States citizenship. The BIA dismissed the appeal, concluding that the IJ's decision became administratively final upon Petitioner's waiver of appeal. The First Circuit denied Petitioner's petition for review, holding that there was not a genuine issue of material fact that, if resolved in Petitioner's favor, would support a finding that he was a U.S. citizen. View "Robinson v. Garland" on Justia Law

Monterey is an independent public agency responsible for analyzing Monterey County's water resources. Cal-Am is an investor-owned water utility providing water to over 100,000 residents on the Monterey Peninsula. Marina, a public agency, provides water for the City of Marina and neighboring Monterey Peninsula communities. In 1995 the State Water Resources Control Board ordered Cal-Am to stop drawing water from the Carmel River and develop an alternate water supply. In 2009 Marina, Monterey, and Cal-Am agreed to develop and construct a regional desalinization project to extract brackish water from beneath Monterey Bay, purify it, and deliver it to consumers. In 2010-2011, the parties entered into several agreements. The project was never built. The parties engaged in negotiation and mediation, ending in January 2012 without resolution.In September 2012, Cal-Am submitted a claim under the California Government Claims Act. Litigation followed. In 2019, the trial court entered summary adjudication against Monterey, finding that a negligence cause of action was barred by the two-year statute of limitations and against Cal-Am under the Government Claims Act. The court of appeal reversed. The trial court erred in finding that the “harm” accrued in 2010. There were triable issues of fact as to express waiver and as to the applicability of alternatives to the Claims Act. View "California-American Water Co. v. Marina Coast Water Districtw" on Justia Law

Section 20.5 of North Carolina’s 2017 Farm Act contains provisions making it illegal to enter into two types of contractual agreements: (1) any settlement agreement conditioned on an agricultural producer’s union affiliation (the Settlement Provision) and (2) any agreement that would require an agricultural producer to process dues checkoffs for its farmworker-employees (the Dues Provision). The Farm Labor Organizing Committee and others (collectively, FLOC) contend that these prohibitions violate the First Amendment, Fourteenth Amendment, and 42 U.S.C. Section 1981. FLOC initiated this action against the Attorney General of North Carolina and the Governor of North Carolina (collectively, the State). The district court held that the Settlement Provision violated the Constitution and so enjoined it, but upheld the constitutionality of the Dues Provision, and then held that neither provision violated Section 1981.   The Fourth Circuit reversed the judgment of the district court as to the Settlement Provision and vacated the accompanying injunction, but affirmed in all other respects. The court explained that a rational basis supports Section 20.5. Agriculture is North Carolina’s largest industry, which makes it a subject of great interest for state legislators. The state also embraces its right-to-work policies and has worked repeatedly to strengthen them. In addition to these general bases for enacting Section 20.5, both challenged provisions respond to discrete legislative concerns. Further, the Settlement Provision prohibits parties from conditioning a settlement agreement on an agricultural producer’s union affiliation. Thus, the court rejected the broad reading advanced by FLOC and adopted by the district court that this statutory provision bars any settlement agreement between an agricultural producer and labor union. View "Farm Labor Organizing Committee v. Joshua Stein" on Justia Law

Plaintiff appealed from the decision rendered in the Eastern District of North Carolina in 2021 granting summary judgment to several officials of North Carolina’s Central Prison (the “Central Prison defendants”), against whom Plaintiff— a Central Prison inmate — pursued various state and federal claims. In awarding judgment to the Central Prison Defendants, the district court ruled that Plaintiff had failed to exhaust all administrative remedies available to him prior to filing his lawsuit in federal court, as required by the Prison Litigation Reform Act (the “PLRA”).   The Fourth Circuit vacated and remanded. The court explained that in these circumstances, however, the record presents numerous disputed issues of material fact about how North Carolina’s prison grievance procedure functions and is administered, including whether Plaintiff failed to exhaust administrative remedies of his own accord and whether such remedies were meaningfully “available” to him. Accordingly, because the district court’s award of summary judgment was erroneously premature and otherwise flawed. View "Matthew Griffin v. Nadine Bryant" on Justia Law

The First Circuit denied a petition for review sought by Petitioners, four individuals who left El Salvador for fear of harm at the hands of a gang, holding that the decision of the Board of Immigration Appeals (BIA) was supported by substantial evidence in the record.After Petitioners were charged as removable they conceded removability but cross-applied for asylum, withholding of removal, and relief under the United Nations Convention Against Torture. An immigration judge (IJ) rejected Petitioners' claims for relief, concluding that Petitioners failed to show that their claimed persecution bore a nexus to a protected ground. The BIA affirmed. The First Circuit denied Petitioners' petition for review, holding that the agency's determination that family membership was not a central reason for Petitioners' persecution was supported by substantial evidence in the record. View "Jimenez-Portillo v. Garland" on Justia Law

An elementary school nurse who unsuccessfully attempted to save the life of a choking child sought workers’ compensation benefits for mental health problems she attributed to the incident. She argued that she suffered post-traumatic stress disorder (PTSD) due to exposure to the child’s bodily fluids and resulting risk of disease and to the mental stress of the incident. The Alaska Workers’ Compensation Board denied her claims, concluding that her exposure to bodily fluids was not a sufficient physical injury to trigger a presumption of compensability and that the mental stress of the incident was not sufficiently extraordinary or unusual to merit compensation. The Board was most persuaded by the opinion of the employer’s medical expert that the nurse’s mental health problems were the result of a pre-existing mental health condition and were not caused by the incident. The Alaska Workers’ Compensation Appeals Commission affirmed. After review, the Alaska Supreme Court found: (1) the Board failed to recognize the link between exposure to bodily fluids and mental distress over the risk of serious disease, which under Alaska precedent was enough to establish a presumption that the mental distress is compensable; and (2) the Board failed to consider the particular details of the child’s death and the nurse’s involvement when it concluded as a general matter that the stress of responding to a choking incident at school was not sufficiently extraordinary to merit compensation for mental injury. However, because the Board found in the alternative that the incident was not the cause of the nurse’s mental health problems, and because both the Commission and the Alaska Supreme Court had to respect the Board’s credibility determinations and the weight it gave conflicting evidence, the denial of benefits was affirmed. View "Patterson v. Matanuska-Susitna Borough School District" on Justia Law

Casey N. sued the County of Orange (the County) and two employees of the County’s Social Services Agency (the Agency) for violating her civil rights in connection with a dependency proceeding involving Casey’s minor child. A jury found in Casey’s favor and awarded her damages. After review, the Court of Appeal affirmed: (1) the trial court did not err by failing to determine the materiality of allegedly fabricated or misrepresented evidence or omitted exculpatory evidence before giving the case to the jury for deliberation; (2) the jury’s verdict against the employees was supported by substantial evidence; (3) the employees were not entitled to qualified immunity; and (4) the jury’s verdict against the County under Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (1978) was supported by substantial evidence. View "Casey N. v. County of Orange" on Justia Law

Before registering a pesticide, EPA must consult with the statutorily specified agencies that have expertise on risks to species’ survival. But for decades, the EPA skipped that step when it registered pesticides, including those at issue in this case. After the EPA went ahead and approved the five registrations, the Conservation Groups petitioned the D.C. Circuit court to invalidate them. The parties then jointly requested that the court hold the petitions in abeyance to allow for settlement negotiations.The parties arrived at the terms of a settlement allowing the registrations to stand if EPA fulfills core ESA obligations by agreed deadlines. As a condition of their settlement agreement’s binding effect, the parties then jointly moved for an Order returning the cases to abeyance until the specified deadlines to afford EPA time to comply with the parties’ settlement terms.The D.C. Circuit agreed with the Order of Consent and held in the case in abeyance. However, the court dismisses as moot the challenge to the registration of cuprous iodide based on the parties’ report that EPA has complied to their satisfaction with the proposed settlement regarding that pesticide ingredient. View "Center for Biological Diversity v. EPA" on Justia Law

Appellants, three Sikh men, intended to join the Marines. However, existing Marines pre-enlistment requirements pertaining to hair length, beards, and a prohibition on wearing certain non-uniform items, conflicted with their faith. The Marines allowed an accommodation, but only after the men completed basic training.Appellants sought a preliminary injunction, and the district court refused. After considering the competing interests in the case, the D.C. Circuit reversed the decision as it related to two men, finding that they showed a likelihood for success on the merits and proved irreparable harm. The court remanded the third man's case for further proceedings. View "Jaskirat Singh v. David Berger" on Justia Law