Justia Government & Administrative Law Opinion Summaries

An Oregon nonprofit organization, whose board members are guided by sincerely held religious beliefs, challenged a state law requiring most employers to provide insurance coverage for abortion and contraceptive services. The organization’s governing documents and public statements reflect a commitment to traditional Judeo-Christian ethics, including opposition to abortion based on religious grounds. Although the law contains exemptions for certain religious employers, the organization does not qualify for any of these exceptions, a point not disputed by the state. The organization sought relief, arguing that being compelled to provide such coverage violates its rights under the First and Fourteenth Amendments.The United States District Court for the District of Oregon denied the organization’s request for a preliminary injunction and dismissed its complaint. The district court found there was doubt as to whether the organization’s opposition to abortion was genuinely religious in nature. It further concluded that the law was neutral and generally applicable, subject only to rational basis review, which it satisfied.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal and vacated the denial of a preliminary injunction. The Ninth Circuit held that the organization’s beliefs are religious and sincerely held, and that the district court erred by not accepting these allegations as true at the motion to dismiss stage. The appellate court remanded the case for the district court to reconsider, in light of the Supreme Court’s decision in Catholic Charities Bureau, Inc. v. Wisconsin Labor & Industry Review Commission, whether the selective denial of a religious exemption to the organization violates the First Amendment. The Ninth Circuit expressed no opinion on the ultimate constitutional question, leaving it for the district court to address in the first instance. View "OREGON RIGHT TO LIFE V. STOLFI" on Justia Law

A group of grocery retailers and public interest organizations challenged federal regulations that established a national uniform disclosure standard for foods containing genetically modified ingredients. Congress had directed the Secretary of Agriculture to create this standard, which was delegated to the Agricultural Marketing Service (AMS). The AMS’s regulations, effective January 1, 2022, required certain foods to disclose if they were “bioengineered” or contained “bioengineered” ingredients, but generally excluded highly refined foods where genetically modified material was undetectable. Plaintiffs argued that this exclusion, the mandated use of the term “bioengineered” instead of more familiar terms like “GMO,” and the allowance of QR code and text-message disclosure options were unlawful or arbitrary under the Administrative Procedure Act (APA).The United States District Court for the Northern District of California granted summary judgment to the plaintiffs only on their challenge to the QR code and text-message disclosure options, remanding those provisions to the AMS without vacating them. The court denied summary judgment on all other claims, which the Ninth Circuit construed as a final judgment granting summary judgment to the AMS and intervenor-defendants on the remaining claims. Plaintiffs appealed.The United States Court of Appeals for the Ninth Circuit held that the plaintiffs had standing and that the AMS committed legal error by generally excluding highly refined foods from the definition of “bioengineered foods.” The court reversed the district court’s grant of summary judgment to the defendants on this issue, remanded with instructions to grant summary judgment to the plaintiffs, and directed the district court to determine whether any regulatory provisions should be vacated. The Ninth Circuit affirmed the district court’s rejection of the claim that the use of “bioengineered” was arbitrary and capricious, finding the agency’s choice reasonable. The court also held that the district court abused its discretion by not vacating the two disclosure-format regulations and directed prospective vacatur after further input from the parties. The judgment was otherwise affirmed. View "NATURAL GROCERS V. ROLLINS" on Justia Law

A candidate for Congress, who holds both a medical degree and a law degree but is not licensed to practice medicine, referred to himself as “Dr. Gonzalez” and a “physician” during his campaign. The Texas Medical Board (TMB) received a complaint alleging that these statements constituted the unlicensed practice of medicine and improper use of professional titles. After an investigation and hearing, TMB determined that the candidate had violated the Medical Practice Act and the Healing Art Identification Act, issuing a cease-and-desist order prohibiting him from using the titles “doctor,” “physician,” or “Dr.” without clarifying his lack of a medical license. The candidate challenged the order, arguing both statutory and constitutional grounds, including that the statutes violated his free speech rights.The Travis County District Court dismissed all of the candidate’s claims for lack of jurisdiction. The Court of Appeals for the Third District of Texas affirmed the dismissal of most claims, holding that the redundant-remedies doctrine barred his ultra vires and as-applied constitutional claims because he could have sought relief through the Administrative Procedure Act (APA). However, the appellate court remanded his facial constitutional challenge to the district court for further proceedings.The Supreme Court of Texas reviewed the case and held that the redundant-remedies doctrine did not bar the candidate’s ultra vires and as-applied constitutional claims, because the relief he sought—declaratory and injunctive relief against future enforcement—went beyond what the APA could provide. The court affirmed the dismissal of his substantial-evidence claim for lack of jurisdiction, as there was no statutory basis for judicial review outside the APA. The Supreme Court of Texas reversed in part, affirmed in part, and remanded for further proceedings on the facial constitutional, as-applied constitutional, and ultra vires claims. View "GONZALEZ v. TEXAS MEDICAL BOARD" on Justia Law

A young adult, H.T., was adjudicated a ward of the court after admitting to a crime and was committed to a secure youth treatment facility. Upon completion of his baseline term, the juvenile court prepared to discharge him to probation supervision in the community. However, finding suitable housing proved difficult due to probation conditions: H.T. could not live with his mother, was ineligible for community organization housing due to a registration requirement, and could not be placed in the probation department’s usual facility because of its proximity to a high school. H.T. requested that the court order the County of Sacramento to pay for his stay at a transitional housing facility.The Superior Court of Sacramento County initially granted H.T.’s request for 30 days of housing but later declined to order further payments, concluding it lacked statutory authority to require the County to pay for H.T.’s housing. The court instead directed the probation department to provide hotel vouchers and other support. H.T. appealed the orders denying his requests for continued payment of rent at the transitional housing facility.The California Court of Appeal, Third Appellate District, reviewed the case. It held that the juvenile court had discretion under Welfare and Institutions Code section 900, subdivision (b), to order the County to pay for the support and maintenance of a ward, including necessary housing expenses. The appellate court found that the lower court misinterpreted its authority and abused its discretion by failing to recognize the full scope of its statutory power. The Court of Appeal vacated the juvenile court’s order and remanded the matter for the juvenile court to exercise its discretion under the correct legal standard, specifically to determine whether payment for H.T.’s housing was necessary at the relevant time. View "In re H.T." on Justia Law

Donald Roberts and Gun Owners of America challenged the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) after the agency issued a 2020 advisory instructing gun sellers not to accept Michigan concealed-pistol licenses as substitutes for the federally required National Instant Criminal Background Check System (NICS) check. Roberts was denied a gun purchase when he presented his Michigan license, prompting the lawsuit. The plaintiffs sought an injunction against enforcement of the advisory and a declaration that the ATF had exceeded its authority under the Administrative Procedure Act.The United States District Court for the Eastern District of Michigan initially granted summary judgment to the ATF on the merits. On appeal, the United States Court of Appeals for the Sixth Circuit vacated that order and remanded for further consideration of state law requirements. On remand, the district court dismissed the complaint for lack of standing, leading to another appeal.After the district court’s dismissal, the ATF issued a new advisory in May 2025, following a presidential executive order, which recognized Michigan licenses as valid alternatives to NICS checks and superseded the 2020 advisory. The United States Court of Appeals for the Sixth Circuit determined that these developments rendered the case moot, as the challenged policy was no longer in effect and the plaintiffs sought only prospective relief. The court found that neither the voluntary cessation nor the capable-of-repetition exceptions to mootness applied. Accordingly, the Sixth Circuit vacated the district court’s dismissal for lack of standing and remanded with instructions to dismiss the case as moot. View "Gun Owners of America, Inc. v. Dep't of Justice" on Justia Law

The dispute centers on groundwater management in the Tulare Lake groundwater subbasin, a high-priority basin under California’s Sustainable Groundwater Management Act (the Act). Local groundwater agencies developed and submitted a sustainability plan for the subbasin, but the Department of Water Resources twice found the plan inadequate. Following these determinations, the State Water Resources Control Board designated the Tulare subbasin as probationary, triggering state intervention and new monitoring, reporting, and fee requirements. In response, Kings County Farm Bureau and other parties filed a writ of mandate and complaint, challenging the State Board’s authority and actions, including the probationary designation and associated fees.The Superior Court of Kings County reviewed the Farm Bureau’s claims. It granted a preliminary injunction halting the State Board’s implementation of the probationary designation and denied in part the State Board’s demurrer to the complaint. Specifically, the trial court dismissed the equal protection claim with leave to amend but allowed the Farm Bureau to proceed on claims alleging improper underground regulations, unconstitutional fees, and general declaratory relief. The State Board then sought appellate review of the trial court’s order overruling its demurrer.The California Court of Appeal, Fifth Appellate District, reviewed the trial court’s decision de novo. It held that the Act exempts the State Board’s actions under the relevant statutory sections from the Administrative Procedures Act, precluding claims based on alleged underground regulations. The court further found that challenges to the extraction fees as unlawful taxes are barred by the “pay first” rule, requiring payment before judicial review. Finally, the court determined that declaratory relief is unavailable where the Legislature has provided a writ of mandate as the exclusive remedy. The appellate court issued a writ of mandate directing the trial court to vacate its order overruling the demurrer and to grant the demurrer without leave to amend as to the sixth, seventh, and ninth causes of action. View "State Water Resources Control Bd. v. Super. Ct." on Justia Law

This case concerns the State Water Resources Control Board’s designation of the Tulare Lake groundwater subbasin as a probationary basin under the Sustainable Groundwater Management Act (the Act). The Act requires local groundwater agencies to develop and implement sustainability plans for high-priority basins, subject to state review. In the Tulare subbasin, five local agencies collaborated on a single plan, which the Department of Water Resources twice found inadequate. Following these findings, the State Board designated the basin as probationary, triggering additional monitoring, reporting, and fee requirements for groundwater extractors. The Kings County Farm Bureau and other plaintiffs challenged the State Board’s actions, alleging the Board exceeded its authority, failed to properly consider requests for exclusion from probationary status, and did not provide adequate notice.The Superior Court of Kings County reviewed the Farm Bureau’s petition and complaint, which included multiple causes of action. The trial court granted a preliminary injunction barring the State Board from enforcing requirements stemming from the probationary designation and imposed only a nominal bond. The court found the Farm Bureau likely to succeed on several claims, including improper denial of the “good actor” exclusion, exceeding statutory authority, and failure to provide required notice. The State Board appealed the injunction and related orders.The California Court of Appeal, Fifth Appellate District, reviewed the preliminary injunction. The appellate court held that the trial court abused its discretion by issuing an overly broad injunction affecting the entire Tulare subbasin, when only certain claims regarding specific groundwater agencies were likely to succeed. The appellate court found the trial court erred in its analysis of some claims and that the injunction was not properly tailored to the harm at issue. The order granting the preliminary injunction was reversed and the case remanded for further proceedings. The petition for writ of supersedeas was denied as moot, and costs were awarded to the State Board. View "Kings County Farm Bureau v. State Water Resources Control Bd." on Justia Law

Rocky Freeman was involved in a Brooklyn drug ring and was hired to kill a rival dealer, Freddie Gonzalez, in 1993. He was later arrested and charged in the United States District Court for the Eastern District of New York with drug conspiracy, the Gonzalez murder, and the unrelated murder of Augustin Sosa. At trial, Freeman was convicted of the drug and Gonzalez murder counts but acquitted of the Sosa murder. However, his presentence report (PSR) incorrectly stated that he had committed both murders. Although a judge ordered the error corrected, the PSR was not amended, and the inaccurate report was transmitted to the Bureau of Prisons (BOP). Freeman subsequently endured heightened security conditions in prison, including solitary confinement and severe restrictions, which he later attributed to the erroneous PSR.Freeman discovered the error in 2015 and pursued administrative remedies, including filing an SF-95 form alleging a Federal Tort Claims Act (FTCA) violation. He then filed a civil complaint in the United States District Court for the Middle District of Pennsylvania against the BOP, the U.S. Probation Office (USPO), his unit manager, and probation officers, alleging FTCA and Bivens claims. The District Court dismissed his FTCA claim for lack of jurisdiction and on the merits, and dismissed his Bivens claim for failure to serve the probation officers. Freeman appealed.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that the District Court erred in dismissing Freeman’s FTCA claim for lack of jurisdiction, finding that he had properly presented his claim to the appropriate agency. The court also held that the District Court improperly applied the Prison Litigation Reform Act’s physical injury requirement to the FTCA presentment phase. The Third Circuit reversed the dismissal of the FTCA claim and remanded for further proceedings. However, the court affirmed the dismissal of Freeman’s Bivens claim, concluding that his claim was not cognizable under current Supreme Court precedent. View "Freeman v. Lincalis" on Justia Law

A natural gas pipeline company replaced three aging compressor units along its pipeline, which transports gas from Canada to the Pacific Northwest. The replacements used newer, higher-capacity compressors, but the company initially installed controls to limit their output to match the old units. After completing the replacements, the company sought federal approval to expand pipeline capacity by removing those restrictions and making other upgrades, securing long-term contracts for the added capacity with new customers. The company excluded the cost of the earlier compressor replacements from the expansion’s cost estimate, assuming those costs would remain allocated to existing customers.The Federal Energy Regulatory Commission (FERC) approved the compressor replacements under its automatic authorization regulation, finding no further environmental review was needed. Later, FERC issued a certificate for the expansion project under the Natural Gas Act, after preparing an environmental impact statement (EIS) as required by the National Environmental Policy Act (NEPA). FERC declined to treat the compressor replacements as part of the expansion for environmental or rate-setting purposes and denied the company’s request for a “predetermination” that expansion costs could be rolled into existing rates in future proceedings. Multiple parties, including two states and environmental groups, sought rehearing and then judicial review, challenging FERC’s decisions on environmental review, rate allocation, and public need.The United States Court of Appeals for the Fifth Circuit reviewed the consolidated petitions. The court held that the pipeline company had standing and its claims were ripe. On the merits, the court found FERC’s decisions were not arbitrary or capricious. FERC reasonably excluded the compressor replacements from the expansion’s environmental and rate analysis, applied its established policies for rate-setting and public need, and provided sufficient environmental review under NEPA. The court denied all petitions for review. View "Gas Transmission Northwest v. Federal Energy Regulatory Commission" on Justia Law

North Mountain Foothills Apartments (NMFA), a company managing a large apartment complex in Phoenix, Arizona, hired Jasper Press as a maintenance technician during a period of increased workload due to a heatwave. Press discussed his compensation and the poor conditions at the complex with several coworkers. Management became aware that other employees knew about Press’s pay and housing benefits, leading to a meeting where Press was reprimanded for these discussions and told not to talk about pest issues with residents. The day after this meeting, Press was terminated, allegedly for failing to complete work orders. Press filed a complaint with the National Labor Relations Board (NLRB), alleging unfair labor practices.An administrative law judge held an evidentiary hearing and found that NMFA violated Section 8(a)(1) of the National Labor Relations Act by interrogating Press about his wage discussions, issuing overly broad directives restricting such discussions, threatening reprisals, and discharging Press for engaging in protected activities. The NLRB adopted these findings and ordered remedies including reinstatement and back pay for Press. NMFA appealed, raising for the first time constitutional challenges to the NLRB’s structure and process, and also contested the Board’s factual findings.The United States Court of Appeals for the Ninth Circuit held that it had jurisdiction to consider NMFA’s unexhausted constitutional claims because such structural challenges are not suited to agency resolution. The court rejected NMFA’s Article II removal protection challenge for lack of demonstrated harm, found no Seventh Amendment right to a jury trial in NLRB proceedings, and held that the combination of investigatory and adjudicatory functions within the NLRB does not violate due process. On the merits, the court found substantial evidence supported the NLRB’s finding that Press was discharged for protected activity and granted enforcement of the NLRB’s order. View "NATIONAL LABOR RELATIONS BOARD V. NORTH MOUNTAIN FOOTHILLS APARTMENTS, LLC" on Justia Law