Justia Government & Administrative Law Opinion Summaries

Plaintiffs (Green Party) brought this action against the Arkansas Secretary of State pursuant to 42 U.S.C. 1983, seeking (1) a declaratory judgment that the Green Party was a political party and that Arkansas Code 7-1-101(21)(C) violated the Green Party's First and Fourteenth Amendment rights and (2) an injunction preventing Arkansas from enforcing section 7-1-101(21)(C). At issue on appeal was whether section 7-1-101(21)(C) severely interfered with the Green Party's right of association and therefore, impermissibly burdened the Green Party's First and Fourteenth Amendment rights. In light of compelling Supreme Court precedent, the many alternative paths Arkansas provided to the ballot, and the Green Party's own success in achieving ballot access, the court held that while the burdens imposed on the Green Party's rights did exist, they were significantly outweighed by Arkansas's important regulatory interests. Therefore, the court concluded that Arkansas's ballot access scheme did not impermissibly burden the Green Party's constitutional rights and the judgment was affirmed.

Appellant alleged that he was disabled as a result of Post Traumatic Stress Disorder, Parkinson's disease, Attention Deficit Disorder, and peripheral neuropathy and that these mental and physical limitations he had as a result of these conditions, combined with his advanced age and limited job skills, rendered him unable to perform any work available in the national economy. Appellant challenged the district court's affirmance of the Social Security Administration's (SSA) denial of his claim for disability benefits. The court affirmed the judgment and held that the ALJ's findings were supported by substantial evidence.

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements.

After concluding that police violated plaintiff's constitutional rights in seizing items from his residence, a Missouri state trial court suppressed the evidence. Missouri filed an interlocutory appeal of the suppression order in the Missouri Court of Appeals, which was dismissed. Plaintiff then brought this civil rights lawsuit against his ex-wife, his son, the City of Desloge, a city police officer, and unidentified defendants. Plaintiff alleged a 42 U.S.C. 1983 claim against all defendants for violations of plaintiff's civil rights, as well as section 1985 and state law claims for civil conspiracy against all defendants. Plaintiff subsequently appealed the dismissal of the city and the police, alleging various errors. The court rejected plaintiff's arguments under State v. Daniels, holding that plaintiff's collateral estoppel argument lacked merit. The court also held that plaintiff's Fourth and Fourteenth Amendment rights were not violated where the arrest warrant was properly admitted and even if the warrant was admitted in error, plaintiff suffered no prejudice. The court further held that plaintiff was unable to show any material prejudice resulting from the late filing of the police's motion to file their brief in opposition to plaintiff's motion for summary judgment. The court finally held that plaintiff failed to establish that the police officer violated plaintiff's constitutional rights and could not maintain the action against the other officer or the city. Accordingly, the judgment of the district court was affirmed.

Plaintiff sued defendant, the Secretary of the Navy, for sexual harassment and retaliation, in addition to state law claims. Plaintiff appealed the district court's dismissal of the case based on the failure to exhaust her administrative remedies. The court affirmed the dismissal and held that plaintiff failed to exhaust her administrative remedies because she first made contact with an Equal Employment Opportunity counselor on February 10, 2004 - 68 days after the sexual harassment ended. The court also held that neither equitable tolling nor equitable estoppel saved her claim.

TCF National Bank (TCF) sued to enjoin a portion of the Dodd-Frank Wall Street Reform Act (Act) of 2010, Pub. L. No. 111-203, 124 Stat. 1376, that would limit the rate some financial institutions could charge for processing debit-card transactions. Section 1075 of the Act, the Durbin Amendment, amended the Electronic Fund Transfer Act, 15 U.S.C. 1693, et seq., by adding several provisions regarding debit-card interchange fees. TCF alleged that section 1693o-2(a)(2), (a)(4), and (a)(6) of the Act were facially unconstitutional because these provisions would require the Board of Governors of the Federal Reserve Board (Board) to set an interchange rate below the cost of providing debit-card services. TCF also alleged that these provisions arbitrarily exempted smaller issuers from the Board's rate regulations and thus violated TCF's due process and equal-protection rights under the Fifth Amendment. The court held that the challenged provisions in the Durbin Amendment survived rational basis review where "Congress's decision to link interchange fees to issuing banks' actual costs was reasonably related to proper legislative purposes: (1) to ensure that such fees were reasonable and (2) to prevent retailers and consumers from having to bear a disproportionate amount of costs of the debit card system." The court also held that the Durbin Amendment's distinction between larger and smaller issuers of debit-cards was rationally related to the government's legitimate interests in protecting smaller banks, which did not enjoy the competitive advantage of their larger counterparts and which provided valuable diversity in the financial industry. Therefore, the court held that TCF was not likely to prevail on its equal-protection argument. Accordingly, the court affirmed the district court's denial of TCF's motion for a preliminary injunction.

Appellant sought disclosure of geospatial data from the USDA under the Freedom of Information Act (FOIA), 5 U.S.C. 552, and the Administrative Procedure Act (APA), 5 U.S.C. 701 et seq. At issue was whether the district court properly dismissed appellant's APA claim and granted summary judgment on its FOIA claim in favor of the USDA. The court held that the district court did not err in concluding that the USDA was not required to disclose the Geographic Information System (GIS) data where it properly determined that the 2008 Farm Bill was a withholding statute for purposes of FOIA exemptions. The court also held that the district court did not err in dismissing the APA claims where FOIA provided an adequate alternative remedy. Accordingly, the judgment of the district court was affirmed.

Plaintiff alleged that defendants violated his procedural due process rights when he was relieved of his responsibilities to fight, inspect, and investigate fires for the Pleasant Hill Volunteer Fire Department. At issue was whether the district court properly granted summary judgment in favor of defendants when plaintiff maintained that a reasonable jury could find that he was a fire code official because he performed some of the duties of a fire code official. Also at issue was whether the district court properly denied plaintiff's motion to reconsider. The court affirmed summary judgment and held that it was undisputed that plaintiff did not exercise many of the most significant responsibilities of a "fire code official" and that there was no evidence in the record that one of the defendants, in her capacity as fire code official, or anyone else, appointed plaintiff as defendants' "duly authorized representative." Therefore, plaintiff did not have a protected property interest in his position to support a due process claim. The court also held that the district court did not abuse its discretion in denying plaintiff's motion to reconsider where his motion was improper for repeating arguments the district court had already rejected in granting defendants' motions for summary judgment and belatedly bringing the Department of Homeland Security ("DHS") applications to the district court's attention, even though the DHS applications were available to him at the time he resisted defendants' summary judgment motion. Accordingly, the judgment was affirmed.

Plaintiff sued defendants, including the police officer that shot him, alleging violations of 42 U.S.C. 1983 and various state law theories. At issue was whether the district court erred by denying the officer's motion for summary judgment on plaintiff's section 1983 claim, concluding that the facts established a violation of the Fourth Amendment and that the law was clearly established at the time of the shooting. The court concluded that it was not clearly established as of the time of the shooting that an officer in Missouri could effect a seizure under the Fourth Amendment without subjectively intending to do so. Therefore, the district court erred in denying the officer's motion for summary judgment on plaintiff's Fourth Amendment claim without considering the officer's subjective intent. Accordingly, the court vacated the section 1983 claim and remanded for further proceedings regarding the officer's subjective intent.

Claimant appealed the district court's judgment upholding the Commissioner of Social Security's denial of her application for disability insurance. Appellant raised several issues of error on appeal. The court held that a certain physician's post-hearing letter did not contain any additional information and was not relied upon in the decision making process, and its receipt did not violate claimant's due process rights; that the ALJ did not err in finding claimant retained the residual functional capacity to perform certain kinds of low-stress work; that there was no error in the decision not to order a consultative examination regarding claimant's mental impairments; and that a hypothetical question posed to the Vocation Expert adequately addressed impairments supported by the record. Accordingly, the court affirmed the judgment where substantial evidence on the record as a whole supported the ALJ's decision.