Justia Government & Administrative Law Opinion Summaries

Plaintiff HVC Inc. was a trustee of the Honda Lease Trust. During the audit period at issue, several car dealerships entered into thousands of leases with customers (lessees) pursuant to lease plan agreements between the dealerships, the trust, and the servicer of the trust. Under the leases, the lessees were responsible for submitting the vehicle registration renewal application and renewal fees to the department of motor vehicles on behalf of the trust. Upon receipt of the renewal application and fee, the department sent the vehicle registration card to the trust, and the trust forwarded the vehicle registration card to the appropriate lessee. After conducting a sales and use tax audit for the audit period from April 1, 2001 through October 31, 2004, Defendant Pamela Law, the then commissioner of revenue services, issued a deficiency assessment against Plaintiff, concluding that the renewal fees constituted taxable gross receipts of the trust and, therefore, were subject to the sales tax. The trial court rendered summary judgment partially in favor of Defendant. The Supreme Court affirmed, holding that the renewal fees paid by the lessess qualified as Plaintiff's gross receipts subject to sales tax under Conn. Gen. Stat. 12-408(1).

Appellants, a group of heirs who were entitled to receive the net proceeds of a judicial sale of four tracts of land, sued Appellees, a former master commissioner of the circuit court, a circuit court judge, and the administrative office of the courts, pursuant to the Kentucky Board of Claims Act, after the former master commissioner failed to disburse the proceeds of the sale. The Board of Claims (Board) entered a final order dismissing Appellants' claims for lack of jurisdiction. The circuit court and court of appeals affirmed. At issue on appeal was whether a claim involving judicial officers or court employes may proceed at the Board. The Supreme Court reversed, holding that the judge's continued use of the master commissioner, without reappointment, to perform significant functions in actions in the circuit court without a bond and without surety approved by the judge as statutorily mandated, was grounds for a claim in the Board of Claims based upon alleged negligence in the performance of a ministerial duty by an officer of the state. Remanded to the Board for a determination of whether Appellants suffered damages as a proximate cause of the alleged negligence.

An elderly woman requiring long-term medical care gave $120,000 to her son in February 2007. The mother believed that the gift would not prevent her from receiving Medicaid coverage if she lived long enough to exhaust her remaining assets. She relied on a provision in Alaska's Medicaid eligibility manual that suggested prospective Medicaid beneficiaries could give away a portion of their assets while retaining sufficient assets to pay for their medical care during the period of ineligibility that Medicaid imposes as a penalty for such gifts. But by the time the mother applied for Medicaid in September 2008, the Alaska legislature had enacted legislation with the retroactive effect of preventing the kind of estate planning the mother had attempted through her gift. The State temporarily denied the mother's application. The son appealed pro se on behalf of his mother, who died in 2009. Upon review, the Supreme Court found that the Alaska legislature's retroactive change to the Medicaid eligibility rules was valid. The Court thus affirmed the State's temporary denial of the mother's application.

Appellee sued the Commissioner of the Social Security Administration (SSA), seeking review of the SSA's denial of benefits to her daughter. At issue was whether a child conceived through artificial insemination more than a year after her father's death qualified for benefits under the Social Security Act, 42 U.S.C. 402, 416. The Commissioner interpreted the Act to provide that a natural child of the decedent was not entitled to benefits unless she had inheritance rights under state law or could satisfy certain additional statutory requirements. The court held that the Commissioner's interpretation was, at a minimum, reasonable and entitled to deference, and that the relevant state law did not entitle the applicant in this case to benefits. Therefore, the court reversed the district court's judgments.

The Industrial Development Board of the City of Montgomery (IDB) appealed a circuit court's interlocutory order that denied its motion for summary judgment as to a breach-of-contract claim asserted against it by George and Thomas Russell as co-executors and co-trustees of the wills and testamentary trusts of Earnest and Myrtis Russell, Price and Mary McLemore and several others. In 2001, various officials of the State of Alabama, the City of Montgomery, the Montgomery County Commission, Montgomery Chamber of Commerce and the local water works board began making preparations to secure options to purchase property in the Montgomery area in an attempt to persuade Hyundai Motor Company to build an automobile plant in the area. All the trusts owned acres of land in the targeted area. The IDB signed separate options with the Russells, the McLemores and other trusts to purchase the respective properties. Hyundai's plans for its manufacturing plant changed, and subsequently, not all of the options were exercised. The Russells and the McLemores each filed breach-of-contract actions against the IDB and Hyundai alleging that neither adhered to the terms of their respective options. Upon review, the Supreme Court found that the trial court did not err in denying the IDB's motion for summary judgment. The Court affirmed the lower court's decision.

Josephine Centorbi died intestate in 2007. At the time of her death, Ms. Centorbi received Medicaid benefits. Ms. Centorbiâs sister, Dianne Fiorille administered the estate, and acting without counsel, applied to relieve the estate from administration. When she filed the application, Ms. Fiorille did not check the box on the form to attest that the decedent was over 55 years old and received Medicaid assistance. In addition, as administrator, Ms. Fiorille failed to file some other forms necessary to notify both the probate court and the Ohio Department of Jobs and Family Services (ODJFS) of the decedentâs death. The probate court granted Ms. Fiorilleâs application to relieve the estate from administration on the same day it was filed. Two years later, ODJFS learned of Ms. Centorbiâs death. It filed an application to vacate the probate courtâs order, but its application was denied. The probate court held that because Ms. Fiorille indicated that no notice was required (in the form of the omitted check box), ODJFSâs application was time barred. The appellate court affirmed the probate courtâs decision. The Supreme Court found that failing to check the box on the initial relief-from-administration form tolled the statute of limitations. Without the check, the Medicaid program had not been officially notified of the decedentâs death. The Court reversed the appellate courtâs decision and remanded the case to the probate court for further proceedings.