Justia Government & Administrative Law Opinion Summaries

A former court reporter who worked for nearly four decades for a California county discovered, as she approached retirement, that the county had failed to enroll her in the state retirement system (CalPERS) for several years early in her employment. Upon learning this, she attempted to secure a complete employment record from the county, which CalPERS required to adjust her retirement benefits. The county failed to provide complete records, reportedly due to records being lost or destroyed, and provided only incomplete information to CalPERS. This left her unable to purchase prior service credit or receive full retirement benefits, causing her financial harm and forcing her to delay retirement.After filing a claim with the county and receiving no response, the plaintiff brought multiple causes of action in the Humboldt County Superior Court, including alleged violations of statutory duties and negligence against the county and individual employees. The trial court sustained the defendants’ demurrers, dismissing all statutory claims without leave to amend and granting leave to amend only the negligence claim. When the plaintiff submitted an amended complaint limited to negligence, the trial court again sustained the demurrer without leave to amend, finding no statutory duty supported the claim.The California Court of Appeal, First Appellate District, Division One, reviewed the case. It held that the plaintiff had stated valid causes of action against the county for violation of mandatory statutory duties to maintain personnel records and to enroll eligible employees in CalPERS under Government Code section 815.6. The court also held, in an unpublished portion, that the plaintiff stated a viable negligence claim against the individual defendants, with the county potentially vicariously liable. The appellate court reversed the trial court’s dismissal of these claims and remanded for further proceedings. View "Gibbs v. County of Humboldt" on Justia Law

A per diem judge had been credited with retirement service by the Employee Retirement System (ERS) for years under a 1990 memorandum that set eligibility criteria. In 2017, the ERS discovered that the Judiciary had not updated personnel forms as the memorandum appeared to require. Without notice or a hearing, ERS issued a new memorandum rescinding the 1990 policy and retroactively stripped the judge’s retirement credits for service after October 1, 2017. The ERS did not follow rulemaking procedures required by Hawaii’s Administrative Procedure Act.The judge administratively challenged the ERS decision. A hearing officer partially sided with her, but the Board of Trustees of the ERS overruled that recommendation and dismissed all claims. The judge appealed to the Circuit Court of the First Circuit, which reversed the ERS Board, finding that both the 1990 and 2017 memoranda were rules under HRS § 91-1 and invalid because they had not been properly promulgated. On appeal, the Intermediate Court of Appeals (ICA) reversed, agreeing that the memoranda were improperly issued but holding that the circuit court’s reasoning did not support the relief granted.The Supreme Court of the State of Hawai‘i reviewed the case. It held that both the 1990 and 2017 memoranda were rules affecting private rights, not mere internal management or intra-agency communications, and thus subject to statutory rulemaking procedures. The 2017 memorandum and its implementing letter were void as to the judge because they were not lawfully adopted and she had timely challenged them. However, because no timely challenge was made to the 1990 memorandum, it remained valid and controlled her eligibility. The Supreme Court vacated the ICA’s decision, reinstated the circuit court’s judgment, and ordered the ERS to credit the judge for eligible service. View "Martel v. Employee Retirement System" on Justia Law

Arthur Miles was sentenced to a total of 300 months’ imprisonment following two separate federal convictions. After his first sentencing in October 2022, Miles was housed at the Marion County Jail in Indiana for fifteen months—some of this time was before and some after his second federal sentencing. During his time at the county jail, Miles worked as an orderly. He later argued that under the First Step Act of 2018 (“FSA”), he was entitled to earn time credits for this work, which could reduce his sentence, because his federal sentence had commenced and the work was equivalent to an evidence-based recidivism reduction (“EBRR”) program.The United States District Court for the District of Massachusetts reviewed Miles’s habeas petition after a magistrate judge recommended denying the Bureau of Prisons’ (BOP) motion to dismiss. The magistrate judge found that BOP regulations preventing prisoners from earning FSA credits until they arrived at a federal facility conflicted with the FSA’s language. The district court, however, rejected this recommendation and dismissed Miles’s petition, holding that the BOP’s rules did not violate the FSA.The United States Court of Appeals for the First Circuit held that the BOP’s regulation, which delayed the accrual of FSA time credits until a prisoner’s arrival at a federal facility, was invalid because it conflicted with the statutory definition of when a sentence commences. The court further held that a risk and needs assessment is not a prerequisite for earning FSA credits, and that prisoners may earn credits for qualifying programming—such as work as an orderly—performed after sentencing even while housed in non-federal facilities. The court vacated the dismissal of Miles’s habeas petition and remanded for further proceedings to determine his entitlement to credits for his time at the county jail. View "Miles v. Bowers" on Justia Law

A federal prisoner was sentenced in December 2020 and, due to pending charges in another jurisdiction, was held at a detention center in Rhode Island rather than being promptly transferred to his designated Bureau of Prisons (BOP) facility in South Carolina. During this period of post-sentencing detention, the prisoner claims to have participated in programs under the First Step Act (FSA), thereby accruing approximately 150 days of time credits, which could reduce his time in custody. However, the BOP did not recognize these credits because he had not undergone a formal risk and needs assessment—the BOP’s prerequisite for awarding such credits—until his eventual arrival at the designated facility in March 2022.After exhausting administrative remedies, the prisoner filed a pro se habeas petition in the United States District Court for the District of South Carolina, seeking recognition of his alleged FSA credits. The magistrate judge, without briefing or discovery, recommended dismissal. The district court adopted this recommendation, concluding that the BOP’s regulation reasonably required an initial assessment before credits could be earned, and applied Chevron deference to uphold the agency's interpretation. The district court also found no evidence the prisoner had “successfully participated” in qualifying programs before arrival at the BOP facility and dismissed the petition without prejudice, refusing to require a government response.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded. The Fourth Circuit held that the case was not moot, as the prisoner could still benefit from the FSA credits if his risk status changed or a warden approved his release. The court further held that, in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference, the district court must independently determine whether the BOP’s interpretation of “successful participation” aligns with the best reading of the statute. View "Benson v. Warden FCI Edgefield" on Justia Law

A parent applied to a state-run program providing compensation for family members who give extraordinary care to individuals with significant medical needs. The applicant’s young child required extensive daily assistance due to chronic health issues. The Department of Health and Human Services denied the application, explaining that the child’s score on a standardized assessment, created internally by the Department, did not meet the minimum threshold to qualify for the program. The assessment assigned points based on responses to a set of questions about the child’s needs, and only those scoring at least fifty percent of possible points for their age group were deemed eligible.After the application was denied, the parent pursued an administrative appeal. The administrative law judge upheld the denial, finding that, under the Department’s rules, only the assessment score determined eligibility for “extraordinary care,” and other medical details were not considered. The Department adopted this finding in a final order and denied a rehearing. The parent then appealed to the District Court of Burleigh County, which affirmed the Department’s decision.On further appeal, the Supreme Court of North Dakota reviewed whether the Department could use the assessment and its scoring rubric to determine eligibility, even though these criteria had not been formally promulgated as administrative rules. The Court held that because these tools operated as binding eligibility requirements of general applicability, they were rules under North Dakota’s Administrative Agencies Practice Act and should have been formally adopted through the rulemaking process. The Court reversed the district court’s order and remanded the case with instructions for further proceedings consistent with its opinion. View "Ferderer v. NDDHHS" on Justia Law

A small convenience store in downtown Los Angeles, owned by an individual, participated in the Supplemental Nutrition Assistance Program (SNAP) and served many customers who used electronic benefit transfer (EBT) cards. In early 2022, the Food and Nutrition Service of the United States Department of Agriculture detected suspicious patterns in the store’s SNAP transactions. Over six months, the store processed hundreds of unusually large transactions, nearly 200 transactions that depleted a household’s monthly benefits in one day, numerous rapid consecutive transactions by the same household, and many transactions for the same dollar amount. Following a physical inspection and review of these patterns, the Agency charged the store with trafficking in SNAP benefits, meaning exchanging benefits for cash or non-eligible goods.After receiving a charge letter and providing a response that generally denied wrongdoing and offered explanations for customer behavior, the store was permanently disqualified from SNAP by the Agency. The owner and the store sought administrative review and submitted additional documents, including affidavits and receipts, but the Agency upheld its decision. The plaintiffs then filed for judicial review in the United States District Court for the Central District of California. The government moved for summary judgment, and the plaintiffs relied on much of the same evidence previously submitted. The district court granted summary judgment for the government, finding that the plaintiffs failed to raise a genuine dispute of material fact as to whether trafficking had occurred.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the government’s evidence established suspicious transaction patterns supporting an inference of SNAP trafficking and that the plaintiffs failed to provide sufficient evidence to create a genuine dispute as to the legitimacy of the flagged transactions. The Ninth Circuit affirmed the district court’s grant of summary judgment in favor of the government. View "BROTHERS MARKET LLC NO. 2 V. USA" on Justia Law

An employee worked for Cowin & Company for nearly three decades, performing construction in coal mines and regularly being exposed to coal dust. Years after his employment ended, he filed a claim for benefits under the Black Lung Benefits Act, alleging total disability due to pneumoconiosis (“black lung disease”) caused by his coal mine work. The claimant relied on a regulatory presumption that applies to miners who have a disabling breathing impairment and at least fifteen years of qualifying coal mine employment. A key dispute in the case involved how to calculate a “year” of coal mine employment under Department of Labor regulations.An administrative law judge initially granted benefits, finding the claimant had at least fifteen years of qualifying employment, thus triggering the presumption. Cowin & Company appealed to the Benefits Review Board, which vacated the benefits award in part and instructed the judge to recalculate the length of coal mine employment, questioning the method used to credit years of employment. On remand, the judge again found more than fifteen years, but the Board disagreed with the method, holding that a claimant must prove both a 365/366-day period of employment and at least 125 working days during that period. Ultimately, after further proceedings, the administrative law judge found only 13.76 years of qualifying employment, and the Board affirmed the denial of benefits.The United States Court of Appeals for the Eleventh Circuit reviewed the Board’s decision. The court held that, under the plain text of the relevant regulation, a claimant establishes a “year” of coal mine employment by showing at least 125 working days in or around coal mines during a calendar year or partial periods totaling one year. The court granted the petition for review, vacated the Board’s decision, and remanded for further proceedings. View "Hayes v. Director, OWCP" on Justia Law

The case concerns significant changes made by the U.S. Department of Housing and Urban Development (HUD) to the Continuum of Care (CoC) program, which provides federal funding for homeless assistance projects. In November 2025, HUD issued a new Notice of Funding Opportunity (NOFO) that rescinded a previously issued two-year NOFO and introduced new requirements, including a drastic reduction in renewal funding for core permanent housing projects and new eligibility conditions. These changes threatened to eliminate funding for many projects, risking increased homelessness in the affected communities. Two groups of plaintiffs, including states, cities, and advocacy organizations, challenged HUD’s actions, alleging violations of the Administrative Procedure Act (APA) and constitutional provisions.The United States District Court for the District of Rhode Island issued preliminary injunctions prohibiting HUD from rescinding the prior NOFO and from implementing the challenged conditions in the new NOFOs. The court found that HUD’s actions likely violated the APA, were arbitrary and capricious, and would cause irreparable harm by creating funding gaps and service disruptions for vulnerable populations. After Congress passed new appropriations legislation in early 2026—setting a structure for grant renewals to avoid funding gaps—HUD moved to dissolve the injunctions, arguing that the legislative changes eliminated any ongoing harm and affected the merits of the legal claims. The district court denied the motion, concluding that the risk of harm persisted and that the plaintiffs remained likely to succeed on their claims.On appeal, the United States Court of Appeals for the First Circuit reviewed only the district court’s denial of HUD’s motion to dissolve the preliminary injunctions. The court held that HUD failed to make a strong showing that the intervening appropriations law eliminated the plaintiffs’ risk of harm or undermined the basis for the injunctions. The First Circuit therefore denied HUD’s request for a stay pending appeal. View "National Alliance to End Homelessness v. Department of Housing and Urban Development" on Justia Law

Two high-ranking Kansas executive officials became embroiled in disputes stemming from federal government actions related to the Supplemental Nutrition Assistance Program (SNAP) and federal grant funding for state agencies. The federal government requested sensitive data from state SNAP programs and threatened to withhold funding if states did not comply. The Kansas Governor viewed these demands as unlawful and opposed compliance, while the Kansas Attorney General disagreed with the Governor’s legal position and asserted that only his office could represent Kansas in related legal challenges. This led to friction over which state official had authority to control litigation involving the state’s interests.The Governor filed a quo warranto petition directly in the Kansas Supreme Court, seeking a declaration that she had constitutional authority to litigate on behalf of the state or, alternatively, on behalf of her office and its agencies. The Attorney General took the position that only he could represent the state as a whole, but conceded there was no objection to the Governor representing her office or executive agencies when they, not the state as a whole, were the real party in interest. The dispute in the lower courts did not involve any jury findings, and the Kansas Supreme Court had original jurisdiction to consider the petition.The Supreme Court of the State of Kansas concluded that, as the case developed, the parties narrowed their disagreement. Both agreed that the Attorney General speaks for the state when the state is the real party in interest, and the Governor speaks for her office or agencies when they are the real party in interest. Because the parties’ positions converged and the remaining dispute was not of significant public importance or suitable for resolution through quo warranto, the Kansas Supreme Court declined to exercise discretionary jurisdiction and dismissed the Governor’s petition. View "Kelly v. Kobach " on Justia Law

A deputy sheriff employed by the Rhode Island Department of Public Safety applied for both ordinary and accidental disability retirement pensions, claiming a back injury sustained in 2011 caused him to stop working in 2020. The Employees’ Retirement System of Rhode Island’s Disability Committee recommended approval of only the ordinary disability pension, finding the accidental disability claim untimely under the statutory filing limits, and noting no evidence of an intervening injury or aggravation. The state retirement board adopted this recommendation and denied the accidental disability pension. Despite submitting additional evidence and requesting rehearing and further medical evaluation, the deputy sheriff’s application continued to be denied by the board, which advised that any appeal could be made in the Superior Court or the Workers’ Compensation Court, if applicable.Following these denials, the deputy sheriff filed appeals in both the Superior Court and the Workers’ Compensation Court. The Employees’ Retirement System moved to dismiss the Workers’ Compensation Court matter, arguing that the court lacked jurisdiction over a state employee’s appeal. The trial judge of the Workers’ Compensation Court denied the motion, concluding that jurisdiction existed based on multiple statutes, including those relating to injured-on-duty payments and the right to appeal denials of accidental disability pensions.The Supreme Court of Rhode Island reviewed the case on certiorari and held that the Workers’ Compensation Court did not have subject matter jurisdiction to hear the deputy sheriff’s appeal. The Court reasoned that the statutory scheme provides for Workers’ Compensation Court jurisdiction only for municipal employees covered under the Optional Retirement Plan, not for state employees like the petitioner, who are covered by the state retirement system. The Supreme Court therefore quashed the trial judge’s order and remanded the case for dismissal due to lack of jurisdiction. View "O'Connell v. Employees' Retirement System of Rhode Island" on Justia Law