Justia Government & Administrative Law Opinion Summaries

Sycamore Cross Solar LLC applied for certificates of public convenience and necessity (CPCN) to construct and operate a solar facility in Isle of Wight County and Surry County, Virginia. The project aimed to generate up to 240 megawatts of power and included transmission lines and associated facilities. The West Virginia & Appalachian Laborers’ District Council (WVALDC) participated in the case, arguing that the State Corporation Commission (Commission) failed to consider the benefits to specific groups as required by the Virginia Clean Economy Act (VCEA) and did not impose a local hiring condition.The Commission conducted an evidentiary hearing where Sycamore, WVALDC, and Commission staff presented their cases. Sycamore's witness testified about the project's economic benefits and commitment to local hiring, though no firm commitment was made. The Hearing Examiner recommended issuing the CPCNs without a local hiring condition but suggested notifying WVALDC about hiring timelines. The Commission adopted the Hearing Examiner's findings but declined the notification requirement, leading WVALDC to seek reconsideration.The Supreme Court of Virginia reviewed the case and affirmed the Commission's decision. The Court held that the VCEA only required the Commission to consider the benefits to specified groups, not make specific findings. The Commission's consideration of the evidence and its decision not to impose a hiring-related condition were within its discretion. The Court found no abuse of discretion, as the Commission reasonably concluded that the statutory requirements were met without the need for additional hiring conditions. View "WVALDC v. State Corporation Commission" on Justia Law

The case involves a challenge by twenty-two states, the District of Columbia, and the Governor of Kentucky against various federal agencies and officials, including the President, regarding the implementation of an Office of Management and Budget (OMB) Directive and related Executive Orders. The OMB Directive, issued on January 27, 2025, required federal agencies to pause the disbursement of federal funds to review their alignment with the President's priorities. The plaintiffs argued that this directive and the subsequent funding freezes were unconstitutional and violated the Administrative Procedure Act (APA).The United States District Court for the District of Rhode Island issued a preliminary injunction on March 6, 2025, against the federal agencies, preventing them from implementing the OMB Directive and related Executive Orders. The court found that the rescission of the OMB Directive did not moot the case, as the funding freezes continued. The court determined that the plaintiffs were likely to succeed on the merits of their APA claims, as the agency actions were arbitrary, capricious, and contrary to law. The court also found that the plaintiffs demonstrated irreparable harm and that the balance of equities and public interest favored granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the defendants' motion for a stay pending appeal, concluding that the defendants failed to make a strong showing of likelihood of success on the merits. The court found that the plaintiffs' challenge was not a broad programmatic attack but targeted discrete final agency actions. The court also determined that the defendants did not demonstrate irreparable harm absent a stay and that the balance of equities and public interest did not favor a stay. View "New York v. Trump" on Justia Law

The case involves the interpretation of the Gun Control Act of 1968 (GCA) in relation to weapon parts kits and unfinished frames or receivers. The GCA mandates that those involved in the import, manufacture, or sale of firearms must obtain federal licenses, keep sales records, conduct background checks, and mark their products with serial numbers. The Act defines a "firearm" to include any weapon that can expel a projectile by explosive action and the frame or receiver of such a weapon. With the rise of weapon parts kits that can be assembled into functional firearms, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) adopted a rule in 2022 to include these kits under the GCA's regulations.The District Court vacated the ATF's rule, agreeing with the plaintiffs that the GCA does not cover weapon parts kits or unfinished frames or receivers. The Fifth Circuit affirmed this decision, holding that the GCA's definition of "firearm" does not extend to weapon parts kits or unfinished frames and receivers, regardless of their completeness or ease of assembly.The Supreme Court of the United States reviewed the case and reversed the Fifth Circuit's decision. The Court held that the ATF's rule is not facially inconsistent with the GCA. The Court found that some weapon parts kits, like Polymer80's "Buy Build Shoot" kit, qualify as "weapons" under the GCA because they can be readily converted into functional firearms. Additionally, the Court held that the GCA's definition of "frame or receiver" includes some partially complete frames or receivers that can be easily finished using common tools. The Court concluded that the ATF has the authority to regulate these items under the GCA. The case was remanded for further proceedings consistent with this opinion. View "Bondi v. Vanderstok" on Justia Law

A Utah-based transportation business, All Resort Group, became insolvent in 2013 due to poor management and financial malfeasance. Two shareholders misappropriated $145,000 in company funds to pay their personal federal tax liabilities. In 2017, the company filed for bankruptcy, and the trustee sought to recover the misappropriated funds under §544(b) of the Bankruptcy Code, invoking Utah’s fraudulent-transfer statute as the applicable law.The Bankruptcy Court ruled in favor of the trustee, holding that §106(a) of the Bankruptcy Code waived the Government’s sovereign immunity for the state-law cause of action nested within the §544(b) claim. The District Court adopted this decision, and the Tenth Circuit affirmed, concluding that §106(a) abolished the Government’s sovereign immunity in an avoidance proceeding under §544(b)(1).The Supreme Court of the United States reviewed the case and reversed the Tenth Circuit’s decision. The Court held that §106(a)’s sovereign-immunity waiver applies only to the §544(b) claim itself and not to the state-law claims nested within that federal claim. The Court emphasized that waivers of sovereign immunity are jurisdictional and do not create new substantive rights or alter pre-existing ones. The Court concluded that §106(a) does not modify the substantive requirements of §544(b) and that the trustee must still identify an actual creditor who could have voided the transaction under applicable law outside of bankruptcy proceedings. View "United States v. Miller" on Justia Law

In 2023, Basin Authority, a Wyoming Child Support Agency, notified Rodolfo P. Munoz that he was in arrears on his child support obligation and began garnishing his social security. Mr. Munoz filed a complaint against the State of Wyoming, the Wyoming Department of Family Services (DFS), and some of its employees, as well as Basin Authority and several of its employees. He alleged breach of contract and violations of due process under 42 U.S.C. § 1983. The district court dismissed Mr. Munoz’s complaint after a hearing.The district court of Big Horn County granted the motions to dismiss filed by the State Defendants and the Basin Authority Defendants. The court found that Mr. Munoz had not made allegations against the State Defendants and that they were not subject to suit under § 1983 because they are not “persons” within the meaning of the statute. The court also found that a breach of contract claim is not actionable under § 1983 and that the alleged agreement was void and unenforceable. Mr. Munoz’s objection and response to the State Defendants’ proposed order on the motion to dismiss and his motion for reconsideration were denied.The Supreme Court of Wyoming reviewed the case and summarily affirmed the district court’s decision. The court noted that Mr. Munoz failed to comply with the Wyoming Rules of Appellate Procedure and did not present cogent arguments supported by pertinent authority. The court emphasized that even pro se litigants must adhere to procedural rules and present coherent arguments. The court concluded that summary affirmance was appropriate due to the deficiencies in Mr. Munoz’s brief and his failure to present relevant legal arguments. View "Munoz v. State of Wyoming" on Justia Law

James and Lori Marlowe own a home on Highway 378 in Florence County, South Carolina. In 2015, the South Carolina Department of Transportation (SCDOT) began construction to widen and realign a portion of Highway 378 adjacent to the Marlowes' home. During the construction, the home flooded twice, once in October 2015 and again in October 2016, during major storm events. The Marlowes filed a lawsuit against SCDOT, alleging inverse condemnation, conversion, due process violations, and negligence.The Circuit Court granted summary judgment in favor of SCDOT on all claims. The Court of Appeals affirmed the Circuit Court's decision on the negligence claim but reversed on the inverse condemnation claim. The Court of Appeals also held that the Stormwater Management and Sediment Reduction Act did not immunize SCDOT from liability. SCDOT petitioned for a writ of certiorari on the inverse condemnation and Stormwater Act issues, which the South Carolina Supreme Court granted.The South Carolina Supreme Court affirmed the Court of Appeals' decision that the Stormwater Act did not immunize SCDOT from liability. However, the Supreme Court reversed the Court of Appeals' decision on the inverse condemnation claim, finding that there was insufficient evidence on the causation issue to allow the claim to proceed. The court held that the evidence, including expert testimony, did not rise above speculation regarding whether the construction of the new roadway caused the flooding of the Marlowes' home. Consequently, the Supreme Court reinstated the grant of summary judgment in favor of SCDOT on the inverse condemnation claim. View "Marlowe v. SC DOT" on Justia Law

The case involves the Environmental Protection Agency's (EPA) disapproval of State Implementation Plans (SIPs) submitted by Louisiana, Texas, and Mississippi under the Clean Air Act (CAA) to address interstate air pollution. The EPA disapproved these SIPs, arguing that they did not meet the requirements of the Good Neighbor Provision, which mandates that states prevent their emissions from significantly contributing to nonattainment or interfering with maintenance of national air quality standards in downwind states.The lower courts had not previously reviewed this case. The case was directly brought to the United States Court of Appeals for the Fifth Circuit, where the petitioners sought to vacate the EPA's disapprovals. The petitioners argued that the EPA's actions were arbitrary, capricious, and inconsistent with the CAA.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court denied the petitions for review from Louisiana and Texas, finding that the EPA's disapprovals were justified based on the states' own data and interpretations of the Good Neighbor Provision. The court concluded that the EPA had reasonably considered the relevant issues and provided adequate explanations for its decisions.However, the court granted the petition for review from Mississippi, vacated the EPA's disapproval of Mississippi's SIP, and remanded the matter to the EPA. The court found that the EPA's disapproval of Mississippi's SIP was arbitrary and capricious because it was based on updated data that was not available to Mississippi at the time of its SIP submission. The court held that the EPA failed to reasonably explain its decision to use this updated data in an outcome-determinative manner. View "Texas v. Environmental Protection Agency" on Justia Law

Plaintiffs, Glacier County taxpayers, alleged that the County and its Commissioners unlawfully made expenditures or disbursements of public funds or incurred obligations in excess of total appropriations, violating Montana law. The case originated from a 2015 lawsuit by Plaintiff Elaine Mitchell, who claimed the County and State failed to comply with the Single Audit Act and the Local Government Budget Act. An independent audit revealed deficit balances in many county funds, prompting the lawsuit. The plaintiffs sought various forms of relief, including declarations of non-compliance with accounting standards and laws ensuring government financial accountability.The Ninth Judicial District Court granted partial summary judgment to Plaintiffs on the issue of the County's improper liquidation of a tax protest fund. Plaintiffs then filed a motion to certify Count II as a class action, which the District Court granted, defining the class as property taxpayers of Glacier County who paid taxes from 2012 to 2020. The County appealed the class certification order and the denial of its motion to dismiss for lack of standing.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decisions. The Court held that Plaintiffs had standing, as they alleged concrete economic injuries from the County's actions, such as increased tax obligations and loss of county services. The Court also found that the class met the prerequisites for certification under M. R. Civ. P. 23(a), including numerosity, commonality, typicality, and adequate representation. The Court ruled that common questions of law and fact predominated over individual questions, making a class action the superior method for adjudicating the controversy. The class certification was affirmed, and the case was remanded for further proceedings. View "Gottlob v. DesRosier" on Justia Law

Nicholas Guthneck was hired by Qlarant Integrity Solutions, LLC, a Maryland company working on federally funded contracts, as a health fraud investigator in September 2020. He worked remotely from Montana. In response to the COVID-19 pandemic, President Biden issued Executive Order 14042 in September 2021, mandating that federal contractors ensure their employees were vaccinated against COVID-19. Qlarant implemented a vaccination policy in October 2021, requiring employees to submit proof of vaccination by November 24, 2021. Guthneck refused to disclose his vaccination status, citing Montana law (House Bill 702, codified as § 49-2-312, MCA), which prohibits employment discrimination based on vaccination status. Consequently, Qlarant terminated his employment on November 4, 2021.Guthneck filed a discrimination complaint with the Montana Human Rights Bureau (HRB), which found reasonable cause to support his claim. The case was set for a hearing before the Office of Administrative Hearings (OAH). Qlarant moved to dismiss the complaint, arguing that Executive Order 14042 preempted Montana law. The OAH hearing officer agreed and dismissed the complaint. Guthneck appealed to the Montana Human Rights Commission (HRC), which vacated the dismissal, stating that the hearing officer lacked authority to determine preemption.Qlarant sought judicial review in the First Judicial District Court, Lewis and Clark County. The District Court reversed the HRC's decision, ruling that the hearing officer had the authority to determine preemption and correctly found that Executive Order 14042 preempted § 49-2-312, MCA. Guthneck appealed to the Montana Supreme Court.The Montana Supreme Court affirmed the District Court's decision. The Court held that the OAH hearing officer had the authority to determine whether Executive Order 14042 preempted Montana law, as it involved statutory interpretation rather than a constitutional question. The Court also held that Executive Order 14042 expressly preempted § 49-2-312, MCA, for federal contractors like Qlarant during the relevant period. Thus, Qlarant was required to comply with the federal mandate, and Guthneck's termination for refusing to disclose his vaccination status was lawful. View "Qlarant v Guthneck" on Justia Law

Several plaintiffs, including United States Sugar Corporation, Okeelanta Corporation, and Sugar Cane Growers Cooperative of Florida, challenged the United States Army Corps of Engineers' approval of the Everglades Agricultural Area Project (EAA Project). The plaintiffs argued that the Corps violated the Administrative Procedure Act by using the wrong water supply baseline in its Savings Clause analysis and by failing to conduct a separate analysis for the standalone operation of the storm water treatment area (STA). They also claimed that the Corps violated the National Environmental Policy Act (NEPA) by not evaluating the effects of the standalone STA operation in its Environmental Impact Statement (EIS).The Southern District of Florida granted summary judgment in favor of the Corps. The district court held that the Corps did not violate the Savings Clause by using the LORS 2008 baseline instead of the year 2000 baseline, as the water supply loss reflected in LORS 2008 was due to structural integrity issues with the Herbert Hoover Dike, not an implementation of the Plan. The court also found that the Corps' decision to use LORS 2008 was reasonable and that the plaintiffs had standing to bring their claims.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision on the plaintiffs' first claim, agreeing that the Corps did not violate the Savings Clause. The court also affirmed the district court's decision on the plaintiffs' third claim, holding that the Corps did not violate NEPA by failing to include the standalone STA operation in its EIS, as the standalone STA had independent utility and could be evaluated in a supplemental EIS.However, the Eleventh Circuit reversed the district court's decision on the plaintiffs' second claim, finding that it was not ripe for review because the Corps had not made a final decision authorizing the standalone operation of the STA. The court remanded the case with instructions to dismiss the second claim for lack of finality and ripeness. View "United States Sugar Corp. v. Army Corps of Engineers" on Justia Law