Justia Government & Administrative Law Opinion Summaries

Two related Wyoming companies, one owning the surface estate and the other owning the mineral estate in an adjacent tract, sought to drill a horizontal well. The plan involved drilling from the surface owner’s land, traversing through federally owned subsurface minerals, and ending in the mineral owner’s adjacent tract. The Bureau of Land Management (BLM), which manages the federal minerals, informed the companies that they needed to obtain a permit to drill through the federal mineral estate, as the process would involve removing a small amount of federal minerals. The companies disagreed, arguing that BLM lacked authority to require a permit for a well that would not produce from the federal minerals, and filed suit seeking a declaration of their right to drill without BLM’s consent.The United States District Court for the District of Wyoming ruled in favor of BLM, holding that Congress had retained sufficient regulatory authority over the mineral estate and had delegated that authority to BLM under the Mineral Leasing Act. The court concluded that BLM could require a permit for the proposed traversing well and that the companies qualified as “operators” under BLM regulations, thus subject to the permit requirement.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case. The Tenth Circuit determined that the dispute was fundamentally about property rights—specifically, whether the surface owner had the right to drill through the federal mineral estate without BLM’s consent. The court held that such disputes must be brought under the Quiet Title Act (QTA), which is the exclusive means for challenging the United States’ title or property interests in real property. Because the companies brought their claim under the Administrative Procedure Act and the Declaratory Judgment Act instead of the QTA, the district court lacked jurisdiction. The Tenth Circuit vacated the district court’s judgment and remanded with instructions to dismiss for lack of jurisdiction. View "True Oil v. BLM" on Justia Law

The case involves a dispute between the owners and operators of a tourist attraction, Bear World, and the Idaho Transportation Department (ITD) over the closure of an intersection on Highway 20 in Madison County, Idaho. Bear Crest Limited LLC owns parcels of land leased to Yellowstone Bear World Inc., and Michael Ferguson is associated with both entities. In 1973, the original landowners (the Gideons) conveyed land to ITD’s predecessor for highway expansion, reserving “Access to the County Road Connection.” In 2016, as part of a highway upgrade to controlled-access status, ITD closed the intersection nearest Bear World, requiring visitors to use a more circuitous route, increasing travel distance by about five miles.After the intersection closure, the plaintiffs sued ITD for breach of contract and inverse condemnation, arguing that the closure violated the reserved access right in the Gideon deed and constituted a taking of property without just compensation. Both parties moved for summary judgment. The District Court of the Seventh Judicial District, Madison County, granted summary judgment to ITD, finding that the deed did not guarantee access to Highway 20, only to a county road, and that the closure did not amount to a compensable taking since alternative access remained.On appeal, the Supreme Court of the State of Idaho reversed in part, vacated the district court’s judgment, and remanded. The Court held that Bear Crest Limited had standing and that the Gideon deed unambiguously reserved access to the specific Highway 20 connection, not merely to a county road. The Court found that ITD’s closure of the intersection breached the deed and substantially impaired Bear Crest’s access rights, constituting a taking under Idaho law. The Court directed entry of partial summary judgment for Bear Crest on both claims, reserving damages and other issues for further proceedings. View "Bear Crest Limited LLC v. State of idaho" on Justia Law

A property owner challenged an annual assessment levied by a city for the maintenance of landscaping and lighting improvements within a maintenance district. The assessment, originally set at $196.23 per residential lot in 1996, had increased to $300 per lot by the 2022–2023 tax year. The property owner argued that this increase violated Proposition 218, a constitutional amendment that restricts local governments’ ability to impose or increase taxes, assessments, and fees without voter approval. The city had not submitted the assessment to voters after Proposition 218’s passage, asserting that the assessment was exempt from Proposition 218’s requirements as a preexisting assessment for certain public services.The Superior Court of California, County of Solano, found in favor of the city. The court determined that the assessment was exempt from Proposition 218 and that the increase to $300 did not constitute an “increase” under the law because it did not exceed a range established before Proposition 218 took effect. Judgment was entered for the city, and the property owner appealed.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. The appellate court held that the assessment had been “increased” within the meaning of Proposition 218 and the implementing statutes because the per-lot rate was higher than the rate in effect when Proposition 218 became law. The court rejected the city’s argument that a flat per-lot assessment does not involve a “rate” and found that the statutory definition of “rate” includes a per-parcel amount. The court also concluded that only ranges adopted in compliance with Proposition 218’s procedures could shield subsequent increases from voter approval requirements. The judgment was reversed and the case remanded for further proceedings consistent with the appellate court’s opinion. View "Thacker v. City of Fairfield" on Justia Law

A group of single-family residential (SFR) water customers challenged the City of San Diego’s tiered water rate structure, which imposed higher rates for increased water usage, arguing that these rates exceeded the proportional cost of service attributable to their parcels as required by California Constitution article XIII D, section 6(b)(3) (enacted by Proposition 218). The City’s water system serves a large population and divides customers into several classes, but only SFR customers were subject to tiered rates; other classes paid uniform rates. The City’s rates were based on cost-of-service studies using industry-standard methodologies, including “base-extra capacity” and “peaking factors,” but the plaintiffs contended these methods did not accurately reflect the actual cost of providing water at higher usage tiers.The Superior Court of San Diego County certified the case as a class action and held a bifurcated trial. In the first phase, the court found that the City failed to demonstrate, with substantial evidence, that its tiered rates for SFR customers complied with section 6(b)(3), concluding the rates were not based on the actual cost of service at each tier but rather on usage budgets and conservation goals. The court also found the City lacked sufficient data to justify its allocation of costs to higher tiers and that the rate structure discriminated against SFR customers compared to other classes. In the second phase, the court awarded the class a refund for overcharges, offset by undercharges, and ordered the City to implement new, compliant rates.On appeal, the California Court of Appeal, Fourth Appellate District, Division Two, affirmed the trial court’s judgment with directions. The appellate court held that the City bore the burden of proving its rates did not exceed the proportional cost of service and that the applicable standard was not mere reasonableness but actual cost proportionality, subject to independent judicial review. The court found substantial evidence supported the trial court’s findings that the City’s tiered rates were not cost-based and thus violated section 6(b)(3). The court also upheld class certification and the method for calculating the refund, and directed the trial court to amend the judgment to comply with newly enacted Government Code section 53758.5, which affects the manner of refunding overcharges. View "Patz v. City of San Diego" on Justia Law

A property owner purchased land in a rural area adjacent to a growing town. After a private developer acquired and sought to develop neighboring tracts, the developer needed sewer access for a new subdivision. The developer attempted to purchase an easement across the property owner’s land, but the owner refused. The developer then persuaded the town to use its eminent domain power to take a sewer easement across the owner’s property, agreeing to cover the town’s costs. The town initiated condemnation proceedings and, before the legal challenge was resolved, installed a sewer line under the property.The Superior Court of Wake County held a hearing and found that the town’s taking was for a private, not public, purpose, rendering the condemnation null and void. The town’s appeal was dismissed as untimely by the North Carolina Court of Appeals, making the trial court’s judgment final. Subsequently, the property owner sought to enforce the judgment and have the sewer line removed, while the town filed a separate action seeking a declaration that it had acquired the easement by inverse condemnation. The trial court denied the owner’s request for injunctive relief and granted the town’s motion for relief from judgment, reasoning that the owner’s only remedy was compensation. The Court of Appeals vacated and reversed in part, holding that injunctive relief might be available but affirmed the denial of immediate removal of the sewer line.The Supreme Court of North Carolina held that when a municipality’s exercise of eminent domain is found to be for a private purpose, title and possession revest in the original landowner. The court further held that the trial court has inherent authority to order a mandatory injunction to restore the property, subject to equitable considerations. The court vacated the town’s separate action as barred by the prior pending action doctrine and remanded for the trial court to determine the appropriate remedy for the continuing trespass. View "Town of Apex v. Rubin" on Justia Law

The case concerns a land exchange between the Bureau of Land Management (BLM) and the J.R. Simplot Company, involving land that was formerly part of the Fort Hall Reservation in Idaho. The Shoshone-Bannock Tribes had ceded this land to the United States under an 1898 agreement, which Congress ratified in 1900. The 1900 Act specified that the ceded lands could only be disposed of under certain federal laws: homestead, townsite, stone and timber, and mining laws. In 2020, BLM approved an exchange of some of these lands with Simplot, who sought to expand a waste facility adjacent to the reservation. The Tribes objected, arguing that the exchange violated the restrictions set by the 1900 Act.The United States District Court for the District of Idaho reviewed the Tribes’ challenge and granted summary judgment in their favor. The court found that the BLM’s approval of the exchange violated the Administrative Procedure Act because it did not comply with the 1900 Act’s restrictions. The court also held, in the alternative, that the exchange failed to meet requirements under the Federal Land Policy and Management Act of 1976 (FLPMA) and the National Environmental Policy Act. The district court certified the case for interlocutory appeal to resolve the legal question regarding the interplay between the 1900 Act and FLPMA.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the 1900 Act’s list of permissible land disposal methods is exclusive and that the BLM’s exchange under FLPMA was not authorized because FLPMA is not among the listed laws. The court further held that FLPMA does not repeal or supersede the 1900 Act’s restrictions, and any ambiguity must be resolved in favor of the Tribes under established Indian law canons. The court concluded that BLM’s authorization of the exchange was not in accordance with law. View "SHOSHONE-BANNOCK TRIBES OF THE FORT HALL RESERVATI V. USDOI" on Justia Law

Two landowners initiated mandamus actions challenging an order issued by a local natural resources district (NRD) that permanently reduced certified irrigated acres on their properties under the Nebraska Ground Water Management and Protection Act. One party, a corporation, owned the affected real estate at the time the administrative proceeding began, while the other acquired ownership only after the proceeding and subsequent appeals had concluded. The NRD’s order stemmed from findings that flow meters on wells had been tampered with, violating district rules. Notice of the proceeding was served on the original landowners and published in local newspapers, but not directly on the corporation.The District Court for Harlan County reviewed the case. It dismissed related declaratory judgment actions but granted mandamus relief to both plaintiffs, finding that the NRD’s order was void as to them because they were not served or made parties to the original administrative proceeding. The court ordered the NRD not to enforce the penalties against the plaintiffs and to take steps to restore their rights to irrigate the affected acres. Attorney fees were also awarded to both plaintiffs.On appeal, the Nebraska Supreme Court found that the corporation was entitled to relief because it was not properly served with notice, rendering the order void as to it. However, the individual who acquired property after the administrative proceeding was not entitled to relief, as the reduction of irrigated acres was completed before he obtained an interest, and the statute does not provide for restoration in such circumstances. The Supreme Court reversed the judgment and attorney fee award for the individual, but affirmed as modified the judgment and attorney fee award for the corporation. The main holdings are: due process requires notice to a corporation owning certified irrigated acres, and a reduction completed before a person acquires an interest is not affected by later acquisition. View "State ex rel. Seeman v. Lower Republican NRD" on Justia Law

The case concerns the Estate of Jack Halverson, which sought to compel the Secretary of the Interior, acting through the Bureau of Indian Affairs (BIA), to partition a parcel of land on the Crow Reservation in Montana. Jack Halverson had owned a significant fractional interest in Allotment 1809 and, in 2015, applied for a partition under federal law. After Halverson’s death, his estate and the BIA entered into a settlement agreement that purported to resolve the partition. The BIA executed deeds to effectuate the partition, but the Estate contended that the BIA failed to assign the ownership interests as required by the agreement, resulting in the Estate receiving a smaller share of land than anticipated.After the BIA recorded the deeds, the Estate moved before an Administrative Law Judge to compel the BIA to comply with the settlement agreement, but the motion was denied. The Estate then filed a mandamus action in the United States District Court for the District of Montana, seeking to compel the BIA to partition the land as agreed. The district court granted summary judgment for the BIA, finding that the agency had fully performed its obligations under the settlement agreement. The Estate appealed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case and determined that the action was barred by sovereign immunity. The court held that a mandamus suit seeking to enforce contract rights against a federal official is, in effect, a suit against the United States, and such suits are barred unless there is a clear waiver of sovereign immunity. The court found no statute waiving immunity for this type of claim. Accordingly, the Ninth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. View "HALVERSON v. BURGUM" on Justia Law

The dispute centers on approximately 930 acres of agricultural land owned by two trusts near Pocatello, Idaho. The trusts entered into a purchase and sales agreement with a developer, Millennial Development Partners, to sell a strip of land for a new road, Northgate Parkway, which was to provide access to their property. The trusts allege that Millennial and its partners, along with the City of Pocatello, failed to construct promised access points and infrastructure, and that the developers and city officials conspired to devalue the trusts’ property, interfere with potential sales, and ultimately force a sale below market value. The trusts claim these actions diminished their property’s value and constituted breach of contract, fraud, interference with economic advantage, regulatory taking, and civil conspiracy.After the trusts filed suit in the District Court of the Sixth Judicial District, Bannock County, the defendants moved for summary judgment. The trusts sought to delay the proceedings to complete additional discovery, arguing that the defendants had not adequately responded to discovery requests. The district court denied both of the trusts’ motions to continue, struck their late response to the summary judgment motions as untimely, and granted summary judgment in favor of the defendants, dismissing the case with prejudice and awarding attorney fees to the defendants. The trusts appealed these decisions.The Supreme Court of the State of Idaho affirmed the district court’s denial of the trusts’ motions to continue, finding no abuse of discretion. However, it reversed the grant of summary judgment, holding that the district court erred by failing to analyze whether the defendants had met their burden under the summary judgment standard and appeared to have granted summary judgment as a sanction for the trusts’ untimely response. The Supreme Court vacated the judgment and remanded the case for further proceedings, and declined to award attorney fees on appeal. View "Rupp v. City of Pocatello" on Justia Law

Members of the Crow Tribe who own trust allotments on the Crow Reservation challenged the loss of their historic water rights following the ratification of the Crow Tribe-Montana Compact and the Crow Tribe Water Rights Settlement Act. The Settlement Act, passed by Congress in 2010, codified a negotiated agreement among the Crow Tribe, the state of Montana, and the United States, which defined tribal water rights and provided substantial federal funding for water infrastructure. In exchange, the Tribe and allottees agreed to waive all other water rights claims. The Act required the Secretary of the Interior to publish a Statement of Findings certifying that certain conditions were met, which would trigger the waiver of prior water rights.After the Secretary published the Statement of Findings in June 2016—following a deadline extension agreed to by the Tribal Chairman and the Secretary—several allottees filed suit nearly six years later. They argued that the extension was invalid because, under the Crow Constitution, only the Tribal General Council or Legislature could authorize such an agreement. They also alleged that the Secretary’s action exceeded statutory authority, breached trust obligations, and violated their Fifth Amendment rights. The United States District Court for the District of Columbia dismissed the complaint for failure to state a claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the dismissal de novo. The court held that the Secretary’s publication of the Statement of Findings constituted final agency action reviewable under the Administrative Procedure Act, but found the Secretary reasonably relied on the Tribal Chairman’s authority to extend the deadline. The court further held that the Settlement Act created specific trust duties, but the plaintiffs failed to plausibly allege any breach. The court also concluded that the plaintiffs’ Fifth Amendment claims for takings, due process, and equal protection failed as a matter of law. The judgment of the district court was affirmed. View "Hill v. DOI" on Justia Law