Justia Government & Administrative Law Opinion Summaries

Several businesses involved in the cultivation, distribution, and sale of hemp products in Wyoming and elsewhere challenged a Wyoming statute, Senate Enrolled Act 24 (SEA 24), which significantly altered the state’s regulation of hemp. SEA 24 narrowed the definition of hemp to exclude synthetic substances and expanded the definition of THC to include both delta-9 and delta-8 THC, requiring that the combined concentration not exceed 0.3%. The law also added both naturally occurring and synthetic delta-8 THC to Wyoming’s Schedule I controlled substances, making it unlawful to manufacture, deliver, or possess hemp products exceeding the new THC limits or containing synthetic substances, even if such products are legal under federal law.After SEA 24 was enacted, the plaintiffs filed a preenforcement action in the United States District Court for the District of Wyoming, seeking declaratory and injunctive relief. They argued that SEA 24 was preempted by the federal 2018 Farm Bill, violated the Dormant Commerce Clause, constituted an unconstitutional regulatory taking, and was void for vagueness. The plaintiffs also sought a temporary restraining order or preliminary injunction to prevent the law from taking effect. The district court denied the motion for preliminary relief and subsequently dismissed the complaint for failure to state a claim, finding that most defendants were protected by Eleventh Amendment immunity and that the remaining claims lacked legal merit.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s dismissal. The court held that the plaintiffs lacked a substantial federal right to support their preemption claim, failed to demonstrate a Dormant Commerce Clause violation, did not establish a regulatory taking of their commercial personal property, and did not show that SEA 24 was unconstitutionally vague. The court also dismissed the appeal of the denial of preliminary relief as moot due to the dismissal of the complaint. View "Green Room v. State of Wyoming" on Justia Law

Residents and the municipality of Morovis, Puerto Rico, brought suit against the Puerto Rico Aqueduct and Sewer Authority (PRASA) and its officials, alleging that for years, Morovis has suffered from a severe water crisis, with many residents lacking water service on most days. The plaintiffs, all PRASA subscribers, claimed that despite repeated notifications and proposed solutions—including a report from the U.S. Army Corps of Engineers—PRASA failed to address the crisis. They alleged that sometimes the outages could be resolved by simply turning on pumps or generators, and that PRASA officials were aware of the situation but did little to provide alternative water sources or adjust billing. The plaintiffs also recounted incidents suggesting deliberate inaction or sabotage by PRASA employees.The United States District Court for the District of Puerto Rico dismissed the case in its entirety at the pleading stage, concluding that the plaintiffs failed to state a claim for a substantive due process violation under the Fourteenth Amendment. The court found that the alleged conduct did not rise to the level of “shocking the conscience,” and also held that the plaintiffs’ contracts with PRASA could not form the basis of a substantive due process claim. The court did not decide whether Puerto Rico law created a protected property interest in water service.On appeal, the United States Court of Appeals for the First Circuit held that the district court erred in dismissing the substantive due process claim. The First Circuit ruled that the plaintiffs plausibly alleged government conduct that could shock the conscience, particularly under a deliberate indifference standard, given the prolonged and severe deprivation of water. The court vacated the district court’s dismissal and remanded for further proceedings, leaving unresolved whether a protected property interest exists and whether qualified immunity applies. View "Maldonado-Gonzalez v. Puerto Rico Aqueduct & Sewer Authority" on Justia Law

A woman with a lifelong hearing impairment obtained a commercial driver’s license (CDL) in New Jersey after receiving a federal exemption from the standard hearing requirement. This exemption allowed her to drive commercial vehicles in interstate commerce but specifically prohibited her from operating passenger vehicles or school buses. Despite this, she was mistakenly issued state endorsements permitting her to drive such vehicles and worked as a campus shuttle bus driver for about eight months. When the New Jersey Motor Vehicle Commission (NJMVC) realized the error, it revoked her passenger and school bus endorsements without providing a pre-revocation hearing.Instead of seeking review in New Jersey Superior Court, the woman filed suit in the United States District Court for the District of New Jersey. She alleged violations of Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and New Jersey’s Law Against Discrimination, as well as a procedural due process claim under 42 U.S.C. § 1983. The District Court dismissed some claims and ultimately granted summary judgment to the defendants on all remaining claims, finding she was not “qualified” for the endorsements and had no property interest in them.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The court held that the plaintiff was not a “qualified individual with a disability” under the relevant statutes because she could not meet the essential eligibility requirement of passing the hearing test for the endorsements. The court also held that, even assuming a property interest in the endorsements, due process did not require a pre-revocation hearing given the state’s strong safety interests and the availability of post-deprivation remedies. The court affirmed summary judgment for the defendants on all claims. View "Parker v. New Jersey Motor Vehicle Commission" on Justia Law

The dispute arose when a property owner obtained a building permit from a city and was required, under the city’s standard procedures, to submit a form containing financial information about subcontractors before the city would conduct necessary inspections and issue a certificate of occupancy. The property owner refused to provide the requested information, leading the city to withhold inspections. As a result, the property owner filed suit, seeking a declaratory judgment that the city lacked authority to require such information and requesting an order compelling the city to perform the inspections. The owner also sought damages for delays allegedly caused by the city’s refusal to inspect.After the property owner settled with the city’s building inspector, the case proceeded in the Baldwin Circuit Court. The jury was asked to decide both the declaratory judgment and damages claims, ultimately finding in favor of the property owner and awarding over $3.5 million in damages. The city appealed. The Supreme Court of Alabama, in a prior decision, held that the damages claim was barred by substantive immunity and reversed the damages award, but did not address the declaratory judgment claim, remanding the case for further proceedings.On remand, the Baldwin Circuit Court entered judgment for the property owner on the declaratory judgment claim but did not award damages. The city appealed again. The Supreme Court of Alabama held that, because the inspections had already been completed and all requested relief had been granted or resolved, no justiciable controversy remained. Therefore, the trial court lacked subject matter jurisdiction to enter a declaratory judgment. The Supreme Court of Alabama reversed the trial court’s judgment and remanded the case for dismissal. View "City of Orange Beach v. Boles" on Justia Law

The case centers on a dispute between a city and a county sheriff regarding the responsibility for accepting and housing individuals arrested by city police officers for on-sight violations of state law, including misdemeanors, at the county jail. In late 2023, the sheriff implemented a policy refusing to accept arrestees from the city without a warrant issued by a county magistrate, even for offenses committed in the presence of city officers. After discussions, the sheriff temporarily relented, and a Memorandum of Understanding (MOU) was executed, allowing the city to transport such arrestees to the county jail. However, this arrangement ended when the sheriff again refused to accept arrestees due to issues with warrant entry procedures and declined to sign a required state form that would have resolved the procedural issue.The Jefferson Circuit Court granted a judgment on the pleadings in favor of the sheriff and the county commission, dismissing the city’s complaint for lack of subject-matter jurisdiction. The trial court found the matter moot, reasoning that the MOU had expired, and concluded that the city’s request amounted to seeking an advisory opinion. The court also dismissed a counterclaim by the county commission.On appeal, the Supreme Court of Alabama determined that the trial court erred in dismissing the complaint for lack of justiciability, finding that a bona fide controversy existed regarding the sheriff’s obligation to accept arrestees without a warrant. However, the Supreme Court of Alabama affirmed the judgment on the pleadings on alternative grounds, holding that no law requires the sheriff to accept arrestees from the city without a warrant, nor is the sheriff required to sign the state form absent a legal obligation. The court concluded that the sheriff and county commission were entitled to judgment as a matter of law. View "City of Birmingham v. Pettway" on Justia Law

A law firm sought to recover over $1.7 million in fees and costs for representing the Los Angeles County Sheriff, Alex Villanueva, and the Sheriff’s Department in litigation initiated by the County of Los Angeles. Due to a conflict of interest, the County’s Board of Supervisors offered Villanueva independent counsel, allowing him to select his attorney but reserving discretion over compensation. Villanueva chose the law firm, which entered into an engagement agreement with him. The County, however, sent its own retainer agreement to the firm, which the firm refused to sign. The firm continued its representation but was never paid. After the firm demanded arbitration under its engagement agreement, the County and related plaintiffs filed suit seeking a declaration that no valid agreement to arbitrate existed and an injunction against the arbitration.The Superior Court of Los Angeles County granted a preliminary injunction, then summary judgment for the County plaintiffs, finding the Sheriff lacked authority to enter into the engagement agreement. The court denied the law firm’s post-judgment motion for leave to file a cross-complaint, citing both untimeliness and bad faith. The firm then filed a separate lawsuit against the County and related defendants, asserting breach of contract and related claims. The trial court sustained the County’s demurrer, dismissing the complaint with prejudice on grounds that the claims were compulsory cross-claims in the earlier action and for failure to allege compliance with the Government Claims Act.The California Court of Appeal, Second Appellate District, Division Eight, affirmed both the judgment in the County’s action and the dismissal of the law firm’s separate lawsuit. The court held that the Sheriff did not have authority to retain counsel on his own; only the Board of Supervisors could contract for legal services. The law firm’s claims were barred as compulsory cross-claims and for failure to comply with the Government Claims Act. View "County of Los Angeles v. Quinn Emanuel Urquhart & Sullivan, LLP" on Justia Law

A deputy marshal who worked at the Eighth Judicial District Court in Clark County received a written reprimand following an internal investigation. The Clark County Deputy Marshals Association, on his behalf, sought a hearing under Nevada statutes that provide procedural protections to peace officers, arguing that deputy marshals are employees of Clark County and thus entitled to such protections. The core dispute centered on whether deputy marshals serving the court are employees of the county or of the court itself.The Nevada Local Government Employee-Management Relations Board determined that deputy marshals are employees of the court, not the county, and therefore not entitled to the protections sought. The appellants then filed a complaint in the district court seeking a declaration that deputy marshals are county employees. All Clark County district judges recused themselves, and the case was assigned to a judge from the Seventh Judicial District Court. That court granted summary judgment to Clark County and the Eighth Judicial District Court, concluding that deputy marshals are employees of the court because their duties are judicial in nature and directly support court operations, rather than general law enforcement functions.On appeal, the Supreme Court of the State of Nevada affirmed the district court’s decision. The Supreme Court held that deputy marshals serving at the Eighth Judicial District Court are employees of the court, not Clark County. The Court reasoned that the judiciary has inherent constitutional authority to employ personnel necessary for its functions, including courtroom security and order, and that deputy marshals’ duties are fundamentally judicial. The Court also held that, although deputy marshals have peace officer powers, they are not part of a law enforcement agency and are not entitled to the procedural protections under NRS Chapter 289. The order granting summary judgment for the respondents was affirmed. View "CLARK CNTY. DEPUTY MARSHALS ASS'N. VS. CLARK CNTY." on Justia Law

A 70-year-old woman was the subject of a state petition for involuntary civil commitment, alleging she suffered from a severe mental disorder with manic and psychotic features. Over several months, she had multiple encounters with law enforcement and was charged with various offenses, including assault and disorderly conduct. The petition included a psychiatric evaluation and described significant behavioral changes affecting her safety and relationships. At the initial hearing, the woman was represented by counsel, who stated she did not want a trial and wished to be stabilized, and the court read her rights aloud.The Eighth Judicial District Court, Cascade County, presided over the hearing. The court relied on the representations of counsel and the woman’s brief affirmations to find that she knowingly and intentionally waived her procedural rights, including the right to contest the commitment. The court then ordered her commitment to the Montana State Hospital for up to 90 days, issuing findings that largely repeated the petition’s allegations. The order stated that the woman and her counsel agreed to waive her rights, but the court did not directly question her about the waiver or develop a record of her understanding.The Supreme Court of the State of Montana reviewed the case. It held that the district court erred by failing to make an adequate inquiry or develop a sufficient record to support a finding that the woman knowingly and intentionally waived her rights, as required by Montana law. The Supreme Court emphasized that merely informing a respondent of their rights or relying on general statements from counsel is insufficient. The order of commitment was reversed, reaffirming the necessity for strict compliance with statutory and due process requirements in involuntary commitment proceedings. View "In re P.G.J." on Justia Law

In this case, the New York Civil Liberties Union (NYCLU) submitted a Freedom of Information Law (FOIL) request to the New York State Office of Court Administration (OCA) after a 2021 internal memorandum discussing a recent court decision was leaked and appeared to have been widely distributed to judges. The NYCLU sought documents created by OCA that provided instructions or guidance to judges on interpreting or applying legal authorities, aiming to understand the scope of OCA’s practice in issuing such memoranda.OCA’s Records Access Officer denied the request, arguing it was overly broad and that any responsive documents were exempt from disclosure as intra-agency materials and protected by attorney-client and work-product privileges. On administrative appeal, OCA maintained these grounds. The NYCLU then initiated a CPLR article 78 proceeding. The Supreme Court, New York County, partially granted the request, finding it sufficiently specific and rejecting the privilege claims. The Appellate Division, First Department, reversed, holding the request was overbroad and, alternatively, that the documents were exempt under attorney-client and work-product privileges. The NYCLU was granted leave to appeal to the New York Court of Appeals.The New York Court of Appeals held that the parties now agree a specific, identifiable set of documents exists that is responsive to the request and can be located by OCA. The Court further held that OCA is not entitled to a blanket attorney-client privilege exemption for all such documents without demonstrating an attorney-client relationship with all Unified Court System judges or reviewing specific documents. The Court reversed the Appellate Division’s order and remitted the matter to Supreme Court for further proceedings, including in camera review of any documents over which OCA continues to assert privilege. View "New York Civil Liberties Union v. State Office of Court Administration" on Justia Law

The petitioner submitted a request under the Freedom of Information Law (FOIL) to the New York City Department of Education (DOE), seeking all emails exchanged between the DOE and a specific domain name over a period from April 2021 to August 2022. The DOE responded that the request did not "reasonably describe" the records because it could not conduct an effective search with reasonable effort, citing technical difficulties in searching its vast email database. The DOE asked the petitioner to narrow the request, but when the petitioner declined, the DOE treated the request as withdrawn.On administrative appeal, the DOE maintained that the request was not reasonably described, as its electronic searches failed to execute due to the large number of email accounts. The petitioner then initiated a CPLR article 78 proceeding, seeking a court order for the DOE to provide the requested records. The Supreme Court denied the petition, and the Appellate Division, First Department, affirmed, holding that the request did not meet the statutory requirement of being "reasonably described" because the DOE could not retrieve the documents through a reasonable electronic search.The New York Court of Appeals reviewed the case and held that the lower courts and the DOE had improperly conflated the requirement that a request "reasonably describe" the records with the separate requirement that an agency retrieve records if it can do so with reasonable effort. The Court clarified that a request is reasonably described if the agency understands what is sought and knows where to look, regardless of the effort required to retrieve it. The Court reversed the Appellate Division’s order and remanded the matter to the DOE for a new determination under the correct legal standard, requiring separate consideration of whether the request was reasonably described and whether the records can be retrieved with reasonable effort. View "Wagner v New York City Dept. of Education" on Justia Law