Justia Government & Administrative Law Opinion Summaries

The plaintiffs, a law firm and its principal, challenged a Montana statute enacted in 2021 that prohibits discrimination based on an individual’s vaccination status or possession of an immunity passport. The law applies broadly to businesses, governmental entities, employers, and public accommodations, with certain exceptions for schools, daycare facilities, and healthcare providers. One provision of the law also prohibits requiring individuals to receive vaccines authorized only for emergency use or still undergoing safety trials. The plaintiffs alleged that the statute violated several provisions of the Montana Constitution, including rights to a clean and healthful environment, equal protection, inalienable rights, and the constitutional requirement that a bill’s subject be clearly expressed in its title.The case was first heard in the District Court of the Seventh Judicial District, Richland County. The District Court denied the plaintiffs’ request for a preliminary injunction and dismissed most of their constitutional claims, but allowed the claim regarding the bill’s title and single-subject requirement to proceed. On remand from the Montana Supreme Court’s earlier decision in Netzer Law Office, P.C. v. State, the District Court ultimately held that the main antidiscrimination provision of the law complied with the constitutional clear-title requirement, but that the provision prohibiting mandates for emergency use or trial vaccines did not, and voided that subsection.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal of the plaintiffs’ other constitutional claims. The Supreme Court held that the law’s title was sufficiently clear and not misleading as to its main antidiscrimination provision, affirming its validity. However, the Supreme Court reversed the District Court’s invalidation of the provision regarding emergency use and trial vaccines, holding that this subsection was germane to the bill’s general purpose and did not violate the clear-title or single-subject requirements. Thus, both challenged provisions of the statute were upheld. View "Netzer v. State" on Justia Law

Phillip Weeks submitted a request under Missouri’s Sunshine Law to the St. Louis Metropolitan Police Department, seeking files containing traffic stop data from 2014 through 2018, specifically in spreadsheet (Excel) format and including officer identification numbers. The Department initially offered to provide traffic analysis reports with redacted officer numbers for a fee, which Weeks declined. During discovery in the resulting lawsuit, the City produced .CSV files containing the requested data. Weeks acknowledged these files matched his request in content but maintained he wanted the data in Excel spreadsheet format. Testimony at trial established that the Department did not maintain the data in Excel format, and there was conflicting evidence about whether the .CSV files could be accurately converted to Excel.The Circuit Court of the City of St. Louis found in favor of the City, concluding that the City did not possess an existing record in the specific format Weeks requested. The court determined that the City had not violated the Sunshine Law because it did not withhold any records it actually maintained in the requested format. Weeks appealed, arguing that the judgment was against the weight of the evidence, and also contended that the City’s admissions during litigation established it had responsive files at the time of his request.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The Court held that Weeks failed to follow the required analytical framework for challenging a judgment as against the weight of the evidence. Specifically, he did not identify all favorable evidence supporting the judgment or address conflicting evidence in accordance with the trial court’s credibility determinations. The Court also found that the City’s admissions did not establish it possessed records in the requested format. The judgment in favor of the City was affirmed. View "Weeks vs. City of St. Louis" on Justia Law

An armed fugitive fleeing law enforcement entered a print shop owned by the plaintiff, forcibly removed him, and barricaded himself inside. After a thirteen-hour standoff, Los Angeles Police Department SWAT officers used dozens of tear gas canisters to subdue the fugitive, causing significant damage to the shop and its contents. The parties agreed that the officers’ actions were authorized, reasonable, and lawful. The plaintiff alleged that the damages, which exceeded $60,000, were caused exclusively by the police.The plaintiff initially sought compensation from the United States Marshals Service, which denied the claim and referred him to the City of Los Angeles. After the City did not respond to his claims or his attorney’s letter, the plaintiff filed a federal lawsuit under 42 U.S.C. § 1983, asserting a violation of the Fifth Amendment’s Takings Clause. The City moved for judgment on the pleadings, arguing that the Takings Clause does not require compensation for property destroyed by police acting reasonably in an emergency. The United States District Court for the Central District of California denied the City’s initial motion but later granted summary judgment for the City, finding that the destruction was a valid exercise of police power and not a compensable taking.The United States Court of Appeals for the Ninth Circuit reviewed the case de novo. The court held that the government’s destruction of private property, when necessary and reasonable for public safety, is exempt from the Takings Clause. The court relied on historical understanding and longstanding precedent, concluding that such actions fall outside the scope of the Takings Clause. Accordingly, the Ninth Circuit affirmed the district court’s judgment, holding that the plaintiff failed to state a claim for a compensable taking under the Fifth Amendment. View "PENA V. CITY OF LOS ANGELES" on Justia Law

The case concerns a challenge to amended energy efficiency standards issued by the U.S. Department of Energy (DOE) for consumer furnaces (specifically, residential non-weatherized gas furnaces and mobile home gas furnaces) and certain commercial water heaters under the Energy Policy and Conservation Act (EPCA). Petitioners, including trade associations, manufacturers, and energy providers, argued that the new standards would effectively eliminate non-condensing appliances from the market, claiming these products offer unique features and performance characteristics not available in condensing models. They also contended that DOE failed to provide adequate economic justification for the new standards and did not comply with procedural requirements during rulemaking.Previously, DOE had issued a series of proposed rules and interpretive rules regarding whether non-condensing technology constituted a protected performance characteristic under EPCA. After public comment and a period of shifting interpretations, DOE ultimately concluded in its 2021 Interpretive Rule that non-condensing technology does not provide a unique performance-related feature compared to condensing appliances. DOE then promulgated final rules in 2023 amending the efficiency standards for both consumer furnaces and commercial water heaters. Petitioners sought review of these actions in the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit held that DOE’s interpretation—that non-condensing appliances do not offer performance characteristics or features substantially different from condensing appliances—was reasonable and supported by the record. The court also found that DOE’s economic justification for the amended standards was robust and supported by substantial evidence (and, for commercial water heaters, by clear and convincing evidence). Additionally, the court determined that DOE provided an adequate opportunity for public comment. Accordingly, the court denied the petitions for review, upholding DOE’s rules. View "American Gas Association v. DOE" on Justia Law

An inpatient rehabilitation facility employed a sales representative who raised concerns about the facility’s use of nonclinical personnel in the preadmission screening process required for Medicare reimbursement. The sales representative was terminated after five months of employment. Shortly thereafter, she filed a qui tam action under the False Claims Act, alleging that the facility presented false claims to Medicare, used false records to obtain payment, and conspired to submit false claims. She amended her complaint multiple times, and the government declined to intervene in the case.The United States District Court for the Southern District of Texas reviewed the second amended complaint after the defendant moved to dismiss under Rule 12(b)(6). The magistrate judge recommended dismissal of all claims, finding the complaint insufficiently plausible and lacking the particularity required by Rules 8(a) and 9(b). The magistrate judge also recommended denying leave to further amend the complaint as futile under Rule 16. The district court adopted these recommendations, entered final judgment, and dismissed the case with prejudice. The plaintiff timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo and the denial of leave to amend for abuse of discretion. The Fifth Circuit held that the complaint failed to plead sufficient facts to support the elements of a False Claims Act violation, specifically the falsity of the claims and the connection between the alleged conduct and the submission of false claims. The court also found that amendment would be futile, as the plaintiff had already amended her complaint twice without remedying the deficiencies. The Fifth Circuit affirmed the district court’s dismissal of the claims with prejudice. View "Gentry v. Encompass Health Rehabilitation Hospital of Pearland, L.L.C." on Justia Law

An Ohio resident was investigated by a county mortgage fraud task force, leading to federal charges for wire fraud and conspiracy, and state charges for related offenses. In federal court, a jury convicted him on most counts, resulting in a lengthy prison sentence. In state court, however, a jury acquitted him of all charges. During the state proceedings, a former task force employee alleged prosecutorial misconduct and was later found deceased, which further motivated the man to seek evidence of government wrongdoing.While incarcerated in Pennsylvania, he submitted Freedom of Information Act (FOIA) requests to the FBI and the Executive Office for United States Attorneys (EOUSA), seeking records related to his cases and the alleged misconduct. After the agencies failed to respond within the statutory timeframe, he filed a civil enforcement action in the United States District Court for the Western District of Pennsylvania. As litigation progressed, both agencies began producing records and provided Vaughn indexes detailing their redactions and withholdings. The plaintiff amended his complaint to add the county task force and a witness as defendants. The District Court dismissed the task force for lack of personal jurisdiction and entered summary judgment for the federal agencies, finding their searches and withholdings adequate.On appeal, the United States Court of Appeals for the Third Circuit affirmed the dismissal of the task force, holding it was not a federal agency and that the District Court lacked personal jurisdiction. The Third Circuit affirmed EOUSA’s search as adequate but found the FBI’s search lacking in scope and method regarding certain records. The court also vacated summary judgment in part, ruling that both agencies failed to sufficiently justify some redactions and withholdings under FOIA exemptions, and remanded for further proceedings consistent with its opinion. The court did not retain jurisdiction over the remanded matters. View "Viola v. US Department of Justice" on Justia Law

Eva Daley, a Guatemalan national, entered the United States as a child without inspection. As an adult, she was convicted of second-degree murder in California, but that conviction was later vacated and replaced with a conviction for assault with a deadly weapon. After serving nearly fifteen years in prison, Daley was detained by U.S. Immigration and Customs Enforcement (ICE) upon her release and transferred to a facility in Colorado. She applied for asylum and related relief, but after over a year in detention without a bond hearing, she filed a habeas corpus petition challenging her continued detention.The United States District Court for the District of Colorado granted Daley’s habeas petition, ordering the government to provide her with an individualized bond hearing. Following the court’s order, an immigration judge held a bond hearing and released Daley on bond after 450 days in ICE custody. Daley then moved for attorneys’ fees under the Equal Access to Justice Act (EAJA), and the district court awarded her $18,553.92 in fees. The government appealed the fee award, arguing that the EAJA does not authorize fees in habeas actions challenging immigration detention.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s fee award de novo, focusing solely on statutory interpretation of the EAJA. The Tenth Circuit held that habeas actions challenging immigration detention are “civil actions” within the meaning of the EAJA, based on common law history, judicial precedent, and statutory text. The court concluded that the EAJA unambiguously authorizes attorneys’ fees in such cases and affirmed the district court’s award of fees to Daley. View "Daley v. Choate" on Justia Law

Hiran Management, a small karaoke restaurant in Houston, Texas, employed eight front-of-house workers who became dissatisfied with their manager’s practices, including being assigned extra duties without increased pay and inconsistent compensation for “shift supervisor” roles. After a contentious meeting with management, the employees walked out, went on strike, and presented a list of demands. The employer subsequently terminated all eight striking employees.Following these terminations, the National Labor Relations Board (NLRB) filed an administrative complaint, alleging that Hiran Management violated section 8(a)(1) of the National Labor Relations Act (NLRA) by firing the employees for engaging in protected concerted activity. An administrative law judge (ALJ) ruled in favor of the NLRB, and the Board adopted the ALJ’s findings with minor adjustments. The Board ordered Hiran to cease its unfair labor practices, reinstate the employees, and compensate them for lost earnings and all other direct or foreseeable pecuniary harms resulting from the terminations.Hiran Management petitioned the United States Court of Appeals for the Fifth Circuit for review, while the NLRB sought enforcement of its order. The Fifth Circuit held that the NLRB lacks statutory authority under the NLRA to award full compensatory damages for all direct or foreseeable pecuniary harms, as such damages are legal rather than equitable remedies. The court granted Hiran’s petition in part, denied the NLRB’s enforcement petition in part, and remanded the case for further proceedings consistent with its opinion, limiting the NLRB’s remedial authority to equitable relief such as reinstatement and backpay. View "Hiran Management v. National Labor Relations Board" on Justia Law

The case concerns multiple petitions for review challenging a Federal Communications Commission (FCC) order that established new rate caps for communications services provided to incarcerated individuals. The FCC’s order, issued pursuant to the Martha Wright-Reed Just and Reasonable Communications Act of 2022, also dismissed as moot certain petitions for clarification and waiver filed by Securus Technologies, LLC, a provider of these services. After the FCC published portions of the order in the Federal Register, several parties—including service providers, advocacy organizations, and state governments—filed petitions for review in various federal appellate courts, contesting different aspects of the order.Following the filing of these petitions, the FCC notified the United States Judicial Panel on Multidistrict Litigation (JPML) under 28 U.S.C. § 2112(a)(3), which randomly selected the United States Court of Appeals for the First Circuit to hear the consolidated petitions. The administrative record was filed in the First Circuit, and subsequent petitions filed in other circuits were transferred there pursuant to statute. Some petitioners, notably Securus and Pay Tel Communications, Inc., argued that the petitions should be transferred to the Fifth Circuit, asserting that it was the proper venue based on the timing and nature of the initial filings. The First Circuit denied these transfer motions, and a request for mandamus to the Supreme Court was also denied.The United States Court of Appeals for the First Circuit held that the petitions for review are properly before it, as the administrative record was filed there pursuant to the JPML’s direction. The court rejected arguments for mandatory transfer to the Fifth Circuit, finding no legal basis to override the JPML’s selection or to collaterally attack its determination. The court also declined to exercise its discretion to transfer the petitions elsewhere. View "Direct Action for Rights and Equality v. Federal Communications Commission" on Justia Law

Several individuals whose livelihoods depended on interacting with spinner dolphins challenged a federal regulation that restricted human proximity to these dolphins. The regulation, known as the Approach Rule, was issued by the National Marine Fisheries Service under the authority of the Marine Mammal Protection Act. The plaintiffs included a psychotherapist who used dolphin encounters in therapy, a boat captain who operated dolphin swim tours, and a dolphin guide and photographer. They argued that the regulation was unconstitutional because it was signed and promulgated by an official who, they claimed, was not properly appointed under the Appointments Clause of the U.S. Constitution.The United States District Court for the District of Maryland reviewed the case after the plaintiffs filed suit seeking to invalidate the regulation and enjoin its enforcement. During the litigation, Dr. Richard Spinrad, the Senate-confirmed NOAA Administrator and a principal officer, ratified the regulation, affirming that he independently evaluated and approved it. The district court found that this ratification cured any potential Appointments Clause defect and granted summary judgment in favor of the government. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that, under established principles of agency law, a principal officer’s ratification of a regulation can cure any constitutional defect arising from its initial promulgation by a non-principal officer. The court found that Dr. Spinrad’s ratification was valid and not impermissibly retroactive, as it did not impose new liabilities for past conduct but merely confirmed the regulation’s validity from the time of its original publication. Accordingly, the Fourth Circuit affirmed the district court’s dismissal of the suit. View "Wille v. Lutnik" on Justia Law