Justia Government & Administrative Law Opinion Summaries

In 2019, New York City enacted Local Law No. 97, requiring significant reductions in greenhouse gas emissions from large buildings, aiming for a 40% reduction by 2030 and an 80% reduction by 2050, relative to 2005 levels. Shortly after, New York State passed the Climate Leadership and Community Protection Act (Climate Act), targeting a 100% reduction in greenhouse gas emissions from 1990 levels by 2050, with an interim goal of a 40% reduction by 2030. The Climate Act tasked the Department of Environmental Conservation (DEC) with setting statewide emissions limits and established a Climate Action Council to develop a Scoping Plan for achieving these targets.Plaintiffs, representing residential buildings subject to Local Law No. 97, filed a declaratory judgment action claiming the local law was preempted by the Climate Act. The defendants, including the City of New York and its Department of Buildings, moved to dismiss the complaint. The Supreme Court granted the motion, dismissing the complaint entirely. However, the Appellate Division modified this decision, denying the motion regarding the preemption claim and affirming the rest. The Appellate Division held that the defendants failed to demonstrate that the Climate Act did not preempt Local Law No. 97.The New York Court of Appeals reviewed the case and reversed the Appellate Division's decision. The Court held that the Climate Act does not preempt the field of regulating greenhouse gas emissions. The Court emphasized that the Climate Act's legislative findings and savings clause indicate an intent to allow complementary local regulations. The Court concluded that the State did not express or imply an intent to preempt local efforts to reduce greenhouse gas emissions, and thus, Local Law No. 97 is not preempted by the Climate Act. The certified question was answered in the negative, and the defendants' motion to dismiss was granted. View "Glen Oaks Vil. Owners, Inc. v City of New York" on Justia Law

Five individuals experienced significant delays in receiving food assistance (SNAP or P-EBT), TANF, or Medicaid benefits. Each requested a hearing before an Administrative Law Judge (ALJ) at the Office of Administrative Hearings (OAH). The ALJs directed the District of Columbia Department of Human Services (DHS) to provide the correct benefits to the claimants, which was eventually done. However, the ALJs also issued orders requiring DHS to correct an "unlawful policy" related to delays caused by internal computer errors or faulty programs.The ALJs' orders were based on the assumption that the delays were due to a systemic issue with DHS's computer systems. DHS representatives mentioned various reasons for the delays, including confusion, human error, and the need for IT tickets to resolve specific issues. In some cases, the delays were attributed to problems with external agencies, such as the Office of the State Superintendent of Education (OSSE). Despite these explanations, the ALJs issued broad orders for DHS to correct its policies.The District of Columbia Court of Appeals reviewed the case and found that the records did not support the conclusion that the delays were due to a DHS policy or systemic computer errors. The court noted that the ALJs did not hold evidentiary hearings or gather substantial evidence to support their findings. The court also found that the ALJs overstepped their authority by issuing broad injunctive relief without a demonstrated need for such measures.The court vacated the challenged orders, concluding that there was no substantial evidence of a DHS policy causing the delays and that the ALJs had not followed proper procedures in issuing their orders. The court emphasized the need for ALJs to base their decisions on substantial evidence and to consider whether broad injunctive relief is necessary. View "District of Columbia Dep't of Human Services v. Butler" on Justia Law

The case involves the City of Lava Hot Springs, which regulates short-term rentals based on whether they are occupied by an owner or manager. Non-owner-occupied short-term rentals are prohibited in residential zones and only allowed in commercial zones. John and Michelle Taylor applied for a business license to operate a non-owner-occupied short-term rental in a residential zone, but the City denied their application. The Taylors, along with the Idaho Association of Realtors, sued the City, claiming that its regulations violated the Short-term Rental and Vacation Rental Act, which limits municipal regulations on short-term rentals.The district court granted summary judgment in favor of the City, finding that the City's regulations did not have the express or practical effect of prohibiting short-term rentals and were permissible under the health, safety, and welfare exception in the Act. The court concluded that because at least one type of short-term rental (owner-occupied) was allowed in residential zones, the City had not violated the Act. The Taylors and the Realtors appealed this decision.The Supreme Court of Idaho reviewed the case and reversed the district court's decision. The Court held that the City's ordinance, which prohibited non-owner-occupied short-term rentals in residential zones, violated the Short-term Rental and Vacation Rental Act. The Act prohibits any city ordinance that has the express or practical effect of prohibiting short-term rentals. The Court found that the City's ordinance amounted to a prohibition rather than a regulation and thus invalidated the ordinance. The Court awarded costs on appeal to the Petitioners but did not grant attorney fees to either party. View "Idaho Association of Realtors, Inc. v. City of Lava Hot Springs" on Justia Law

The City of Oxnard and two other public agencies formed the City of Oxnard Financing Authority through a joint powers agreement. The Financing Authority approved two lease revenue bonds to finance public capital improvements. Moving Oxnard Forward, Inc. and Aaron Starr challenged the approval of these bonds, arguing they violated constitutional debt limits under the California Constitution. The trial court ruled in favor of the City and the Financing Authority, leading the plaintiffs to appeal.The trial court found that the bonds did not require voter approval under the Offner-Dean rule, which allows for contingent obligations that do not create immediate debt. The court also determined that the City and the Financing Authority complied with the procedural requirements of the Joint Exercise of Powers Act in authorizing the bonds. The trial court dismissed other causes of action for writ of mandate/administrative mandamus and declaratory relief, as the plaintiffs had an adequate legal remedy through the reverse validation action.The California Court of Appeal, Second Appellate District, reviewed the case and affirmed the trial court's judgment. The appellate court held that the additional payments required by the lease agreements were not unconstitutional long-term debt obligations, as they were contingent upon the City's use and occupancy of the leased properties. The court also found that the lease-leaseback funding arrangement complied with the Offner-Dean rule and that the City had made a valid finding of significant public benefit under the Marks-Roos Act. The judgment in favor of the City and the Financing Authority was affirmed, allowing the issuance of the lease revenue bonds to proceed. View "Moving Oxnard Forward, Inc. v. City of Oxnard" on Justia Law

Plaintiff Jennifer Restivo was skateboarding on a residential street in Petaluma, California, when her skateboard wheel caught in a large crack, causing her to fall and sustain a serious arm injury. She alleged that the City of Petaluma was negligent in maintaining the street and that the city had sufficient notice of the dangerous condition to repair it before her accident. The city moved for summary judgment, arguing that it had neither actual nor constructive notice of the dangerous condition.The Sonoma County Superior Court granted summary judgment in favor of the city. The court found that there was no triable issue of material fact regarding the city's notice of the dangerous condition. The court noted that the city had maintained records of complaints about city streets for over ten years and had received no complaints about the street in question. Additionally, the city engineer testified that the city had conducted inspections of the street and found no significant issues that required repair.The California Court of Appeal, First Appellate District, reviewed the case and affirmed the trial court's decision. The appellate court held that the city had neither actual nor constructive notice of the dangerous condition. The court emphasized that the city's inspection and maintenance practices, including the bi-annual pavement condition reports and subsequent inspections, did not reveal the specific crack that caused the plaintiff's fall. The court also noted that the plaintiff's expert's opinion did not provide sufficient evidence to establish that the city had notice of the dangerous condition.The main holding of the appellate court was that the city did not have actual or constructive notice of the dangerous condition that caused the plaintiff's injury, and therefore, the city was not liable for the plaintiff's injuries. The judgment in favor of the city was affirmed. View "Restivo v. City of Petaluma" on Justia Law

Marc A. Lesperance was found with his dog off-leash in Baxter Woods, Portland, despite a city ordinance requiring dogs to be leashed from April 1 to July 31. A park ranger informed Lesperance of the rule, but Lesperance refused to comply. The ranger, after consulting with a colleague, issued a summons and complaint. The District Court (Portland) fined Lesperance $500, noting it was not his first violation of the ordinance.Lesperance appealed, arguing that the park ranger was not authorized to issue the summons and complaint. He also claimed the city ordinance was preempted by state law and unconstitutionally vague. The court found these arguments without merit, stating the ordinance was clear and not preempted by state law.The Maine Supreme Judicial Court reviewed the case. The court considered whether the park ranger, appointed as a constable, needed to meet specific training requirements to enforce the ordinance. The Attorney General, representing the Maine Criminal Justice Academy, suggested that constables might require less rigorous training than law enforcement officers. The court applied the "de facto officer" doctrine, concluding that Lesperance could not challenge the ranger's authority based on potential training deficiencies. The court affirmed the judgment, validating the ranger's actions as those of a de facto officer. View "City of Portland v. Lesperance" on Justia Law

An inmate at the Richland Correctional Institution, Kimani E. Ware, sought a writ of mandamus to compel Richland County Sheriff Steve Sheldon to provide public records he requested, including a booking report, use-of-force reports, and policies on inmate grievances and use of force. Ware also sought statutory damages and court costs.Ware sent his public-records request in October 2022, and the sheriff's office responded in November 2022. However, there was conflicting evidence regarding the completeness of the sheriff's response. Ware claimed that the sheriff did not provide the inmate-grievance policy and use-of-force policy, and that the sheriff provided incident reports instead of the requested use-of-force reports. Ware filed his mandamus complaint in December 2023, and the sheriff moved to dismiss, which was denied by the court. Both parties submitted evidence, but only Ware filed a timely merit brief.The Supreme Court of Ohio reviewed the case and found discrepancies in the evidence provided by Ware, suggesting that Ware may have altered the response letter from the sheriff's office. The court determined that Ware did not prove by clear and convincing evidence that the sheriff failed to provide the requested records. Consequently, the court denied Ware's claim for a writ of mandamus and his requests for statutory damages and court costs. The court also denied motions from both parties for leave to file additional evidence. View "State ex rel. Ware v. Sheldon" on Justia Law

Miya Water Projects Netherlands B.V. (Miya) filed a lawsuit under the Transparency and Expedited Procedure for Public Records Access Act (TEPPRA) against the Financial Oversight and Management Board for Puerto Rico (the Board). Miya sought access to public records related to a canceled water infrastructure project. The Board, established by Congress in 2016, refused to provide the requested documents, claiming TEPPRA did not apply to it. Miya then sued the Board in the United States District Court for the District of Puerto Rico.The district court dismissed Miya's case, ruling that the Board was protected by Eleventh Amendment immunity, which extends to Puerto Rico. The court applied the arm-of-the-state test and concluded that the Board, as an entity funded by the Commonwealth and with judgments paid by the Commonwealth, shared Puerto Rico's immunity. The court also determined that the Commonwealth did not waive this immunity through TEPPRA, as the statute did not meet the strict standards required to effect such a waiver under federal law.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's decision de novo. The appellate court agreed with the lower court's findings, holding that Puerto Rico's Eleventh Amendment immunity extends to the Board and that the Commonwealth did not waive this immunity through TEPPRA. The court emphasized that a waiver of Eleventh Amendment immunity must be unequivocally expressed in the statute's text, which TEPPRA did not do. Consequently, the appellate court affirmed the district court's dismissal of Miya's claim for lack of subject matter jurisdiction. View "Miya Water Projects Netherlands B.V. v. Financial Oversight and Management Board" on Justia Law

The Federal Communications Commission (FCC) issued an order requiring most television and radio broadcasters to compile and disclose employment-demographics data to the FCC, which would then post the data on its website. Petitioners, a group of broadcasters and associations, challenged the order, arguing that the FCC lacked statutory authority for such a requirement, and that it violated their First and Fifth Amendment rights, and was arbitrary and capricious under the Administrative Procedure Act.The FCC reinstated the collection of employment-demographics data in February 2024, ending a 22-year hiatus. The data collection, through Form 395-B, was intended to monitor industry trends and report to Congress. The FCC had previously collected this data until 2002, when it was suspended following a court ruling that found certain FCC regulations unconstitutional. The FCC's new order also included amendments to Form 395-B, such as adding non-binary gender categories and expanding job categories.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the FCC lacked statutory authority to require broadcasters to submit Form 395-B. The court explained that the FCC's broad public-interest authority must be linked to a distinct grant of authority from Congress, which was not present in this case. The court also rejected the FCC's argument that the 1992 Cable Act ratified its authority to collect Form 395-B data, noting that the Act tied this authority to equal employment opportunity regulations that were no longer in effect.The Fifth Circuit granted the petition and vacated the FCC's order, concluding that the FCC did not have the statutory authority to mandate the collection and disclosure of employment-demographics data from broadcasters. View "National Religious Broadcasters v. FCC" on Justia Law

In April 2021, David Browne visited Billy Jack’s Saloon and Grill in Dewey-Humboldt, Arizona. After leaving the bar, Browne, with a blood alcohol content nearly four times the legal limit, caused a multi-vehicle collision on State Route 69. Victor Sanchez-Ravuelta, Janette Dodge, and their two minor children, Elijah and Amelia, were injured in the crash. The plaintiffs alleged that the Arizona Department of Liquor Licenses and Control (the Department) was negligent in failing to prevent Billy Jack’s from overserving its patrons.The plaintiffs filed a lawsuit against the State of Arizona, the Town of Dewey-Humboldt, and Yavapai County. The Superior Court in Maricopa County dismissed the claims against all defendants. The court found that the plaintiffs’ notice of claim to the County and Town was insufficient and that the Department did not have a legal duty to protect the plaintiffs from the harm caused by Browne’s actions. The court dismissed the minor plaintiffs’ claims without prejudice and the adult plaintiffs’ claims with prejudice.The Arizona Court of Appeals held that the Department owed a statute-based duty of care to the plaintiffs. However, the Arizona Supreme Court reviewed the case and concluded that the Department did not owe a duty of care to the plaintiffs. The court found that the statutes cited by the plaintiffs did not impose a mandatory duty on the Department to prevent the overserving of patrons. The Supreme Court vacated parts of the Court of Appeals' opinion and affirmed the Superior Court’s dismissal of the adult plaintiffs’ claims against the State with prejudice. The case was remanded to the Court of Appeals to consider the Town’s cross-appeal. View "SANCHEZ-RAVUELTA v YAVAPAI" on Justia Law