Justia Government & Administrative Law Opinion Summaries

The case involves a dispute between several plaintiffs, who are foreign nationals participating in an au pair program, and Cultural Care, Inc., a Massachusetts company that places au pairs with host families in the U.S. The plaintiffs allege that Cultural Care violated their rights under the Fair Labor Standards Act (FLSA) and various state wage and hour laws by failing to pay them legal wages. They also claim violations of state deceptive trade practices laws.The United States District Court for the District of Massachusetts denied Cultural Care's motion to dismiss the complaint, including its defense of derivative sovereign immunity under Yearsley v. W.A. Ross Construction Company. Cultural Care appealed, but the United States Court of Appeals for the First Circuit affirmed the District Court's decision, concluding that Cultural Care had not established entitlement to protection under Yearsley. After the case returned to the District Court, Cultural Care filed a motion to compel arbitration based on agreements in contracts signed by the au pairs with International Care Ltd. (ICL), a Swiss company. The District Court denied this motion, ruling that Cultural Care had waived its right to compel arbitration and that it could not enforce the arbitration agreement as a nonsignatory.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's denial of the motion to compel arbitration. The court held that Cultural Care, as a nonsignatory to the ICL Contract, could not enforce the arbitration agreement under either third-party beneficiary theory or equitable estoppel. The court emphasized that the arbitration agreement did not demonstrate with "special clarity" that the signatories intended to confer arbitration rights on Cultural Care. Additionally, the plaintiffs' statutory claims did not depend on the ICL Contract, making equitable estoppel inapplicable. View "Posada v. Cultural Care, Inc." on Justia Law

The U.S. Department of Education announced a reduction in force (RIF) on March 13, 2025, affecting about half of its employees. Subsequently, twenty-one states and several labor organizations and school districts filed lawsuits against the Secretary of Education, the Department, and the President, claiming that the RIF violated the U.S. Constitution and the Administrative Procedure Act (APA). They also sought an injunction against the transfer of certain functions out of the Department, announced by the President on March 21, 2025.The U.S. District Court for the District of Massachusetts consolidated the cases and granted the plaintiffs' motions for a preliminary injunction. The court found that the plaintiffs were likely to succeed on the merits of their claims, determining that the RIF and the transfer of functions were likely ultra vires and violated the APA. The court concluded that the actions were arbitrary and capricious, lacking a reasoned explanation and failing to consider the substantial harms to stakeholders.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the appellants' motion for a stay pending appeal. The court found that the appellants did not make a strong showing that they were likely to succeed on the merits, particularly regarding the APA claims. The court also determined that the plaintiffs would suffer substantial injury without the injunction, as the RIF made it effectively impossible for the Department to carry out its statutory functions. The court concluded that the public interest favored maintaining the injunction to ensure the Department could fulfill its legal obligations. View "New York v. McMahon" on Justia Law

Plaintiffs, who own or operate gasoline service stations in Puerto Rico, offered two different prices to consumers: a higher price for those using credit or debit cards and a lower price for those paying with cash. In 2013, Puerto Rico's legislature enacted Law 152-2013, amending Law 150-2008 by removing a provision that allowed merchants to offer cash discounts. Plaintiffs ceased offering the lower price due to the threat of fines and criminal prosecution. They sued the Commonwealth of Puerto Rico, arguing that Law 150 is preempted by federal law and is unconstitutionally vague.The United States District Court for the District of Puerto Rico rejected the plaintiffs' arguments and granted the Commonwealth's motion to dismiss for failure to state a claim. The court found that neither the Cash Discount Act (CDA) nor the Durbin Amendment preempted Law 150. The court also declined to address the constitutional vagueness argument, noting that the complaint did not allege that Law 150 is unconstitutionally vague.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the CDA and the Durbin Amendment do not preempt Law 150. The CDA regulates the conduct of credit card issuers, not merchants or states, and does not confer an absolute right to offer cash discounts. The Durbin Amendment regulates payment card networks, not states, and does not preempt state legislation restricting cash discounts. The court also found that the plaintiffs did not properly plead a vagueness claim in their complaint, rendering the claim unpreserved for appellate review. Consequently, the First Circuit affirmed the district court's dismissal of the case. View "Asociacion de Detallistas de Gasolina de PR Inc. v. Commonwealth of Puerto Rico" on Justia Law

A Russian citizen, Diana Avdeeva, married a U.S. citizen and applied for lawful permanent-resident status, which was granted on a conditional basis. She and her husband later filed a petition to remove the conditional status, but USCIS did not act on it within the required timeframe. After their divorce, Avdeeva requested the petition be converted to a waiver petition. She then applied for naturalization, but USCIS denied her petition, terminated her permanent-resident status, and placed her in removal proceedings. Avdeeva sued USCIS for failing to adjudicate her naturalization application within the statutory period.The U.S. District Court for the District of Massachusetts remanded the case to USCIS based on a settlement agreement, which required USCIS to terminate removal proceedings, approve her petition, and conduct a new naturalization interview. Avdeeva was naturalized, and she dismissed her other lawsuit. She then sought attorney's fees under the Equal Access to Justice Act (EAJA), but the district court denied her motion, suggesting she was not a "prevailing party" and that awarding fees would be unjust due to the settlement terms.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that Avdeeva was not a "prevailing party" under EAJA because the change in her legal status was not "court-ordered" but rather a result of the settlement agreement. The court noted that the district court's remand order did not resolve the merits of the case or retain jurisdiction to enforce the settlement, thus lacking the necessary judicial imprimatur. Consequently, Avdeeva was not entitled to attorney's fees. View "Avdeeva v. Tucker" on Justia Law

The case involves an enforcement action by the U.S. Securities and Exchange Commission (SEC) against Gregory Lemelson and Lemelson Capital Management, LLC. The SEC alleged that Lemelson made false statements of material fact, engaged in a fraudulent scheme, and violated securities laws, resulting in approximately $1.3 million in illegal profits. The SEC sought disgorgement of these profits, a permanent injunction, and civil monetary penalties. Lemelson moved to dismiss the complaint, and the district court dismissed one of the challenged statements. The SEC filed an amended complaint, and the jury ultimately found Lemelson liable for three statements but rejected other claims.The District Court for the District of Massachusetts held Lemelson in contempt for violating a protective order and threatening a priest who provided information to the SEC. After the jury verdict, the district court issued a final judgment, including a five-year injunction against Lemelson and a $160,000 civil penalty. Lemelson appealed, and the United States Court of Appeals for the First Circuit affirmed the district court's judgment. Lemelson then moved for attorneys' fees and costs under the Equal Access to Justice Act (EAJA), arguing that the SEC's demands were excessive compared to the final judgment.The United States Court of Appeals for the First Circuit reviewed the district court's denial of Lemelson's motion for fees and costs. The appellate court found that the district court incorrectly compared the SEC's demand to the scope of the initial claims rather than the final judgment obtained. The appellate court vacated the denial of fees and costs and remanded the case for further proceedings to determine whether the SEC's demands were excessive and unreasonable compared to the final judgment. The appellate court also noted that the district court should consider whether Lemelson acted in bad faith or if special circumstances make an award unjust. View "Securities and Exchange Commission v. Lemelson" on Justia Law

In 2023, James Broad and Rebecca McCrensky began operating a car-rental agency, Becky's Broncos, LLC, on Nantucket Island without the necessary local approvals. The Town of Nantucket and the Nantucket Town Select Board ordered Becky's to cease operations. Becky's sought preliminary injunctive relief in the District of Massachusetts to continue their business.The District Court for the District of Massachusetts denied Becky's request for a preliminary injunction. The court found insufficient evidence of discriminatory effect under the dormant Commerce Clause and concluded that Becky's had not demonstrated a likelihood of success on the merits of its claims. Becky's appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's denial of the preliminary injunction. The appellate court held that Becky's did not show a likelihood of success on the merits of its dormant Commerce Clause claim, as the ordinance did not discriminate against out-of-state businesses. The court also found that Becky's failed to establish a likelihood of success on its antitrust claims due to a lack of a concrete theory of liability. Additionally, Becky's procedural due process argument was rejected because it did not establish a property interest in the required medallions. Lastly, the court held that the ordinance survived rational basis review under substantive due process, as it was rationally related to legitimate government interests in managing traffic and congestion on the island. View "Becky's Broncos, LLC v. Town of Nantucket" on Justia Law

Miya Water Projects Netherlands B.V. (Miya) filed a lawsuit under the Transparency and Expedited Procedure for Public Records Access Act (TEPPRA) against the Financial Oversight and Management Board for Puerto Rico (the Board). Miya sought access to public records related to a canceled water infrastructure project. The Board, established by Congress in 2016, refused to provide the requested documents, claiming TEPPRA did not apply to it. Miya then sued the Board in the United States District Court for the District of Puerto Rico.The district court dismissed Miya's case, ruling that the Board was protected by Eleventh Amendment immunity, which extends to Puerto Rico. The court applied the arm-of-the-state test and concluded that the Board, as an entity funded by the Commonwealth and with judgments paid by the Commonwealth, shared Puerto Rico's immunity. The court also determined that the Commonwealth did not waive this immunity through TEPPRA, as the statute did not meet the strict standards required to effect such a waiver under federal law.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's decision de novo. The appellate court agreed with the lower court's findings, holding that Puerto Rico's Eleventh Amendment immunity extends to the Board and that the Commonwealth did not waive this immunity through TEPPRA. The court emphasized that a waiver of Eleventh Amendment immunity must be unequivocally expressed in the statute's text, which TEPPRA did not do. Consequently, the appellate court affirmed the district court's dismissal of Miya's claim for lack of subject matter jurisdiction. View "Miya Water Projects Netherlands B.V. v. Financial Oversight and Management Board" on Justia Law

The case involves a challenge by twenty-two states, the District of Columbia, and the Governor of Kentucky against various federal agencies and officials, including the President, regarding the implementation of an Office of Management and Budget (OMB) Directive and related Executive Orders. The OMB Directive, issued on January 27, 2025, required federal agencies to pause the disbursement of federal funds to review their alignment with the President's priorities. The plaintiffs argued that this directive and the subsequent funding freezes were unconstitutional and violated the Administrative Procedure Act (APA).The United States District Court for the District of Rhode Island issued a preliminary injunction on March 6, 2025, against the federal agencies, preventing them from implementing the OMB Directive and related Executive Orders. The court found that the rescission of the OMB Directive did not moot the case, as the funding freezes continued. The court determined that the plaintiffs were likely to succeed on the merits of their APA claims, as the agency actions were arbitrary, capricious, and contrary to law. The court also found that the plaintiffs demonstrated irreparable harm and that the balance of equities and public interest favored granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the defendants' motion for a stay pending appeal, concluding that the defendants failed to make a strong showing of likelihood of success on the merits. The court found that the plaintiffs' challenge was not a broad programmatic attack but targeted discrete final agency actions. The court also determined that the defendants did not demonstrate irreparable harm absent a stay and that the balance of equities and public interest did not favor a stay. View "New York v. Trump" on Justia Law

The case involves a dispute between several states and the U.S. Department of Education regarding the termination of grants for Teacher Quality Partnership (TQP) and Supporting Effective Educator Development (SEED) programs. The Department sent letters to 104 out of 109 grant recipients, stating that their grants were terminated due to involvement in diversity, equity, and inclusion (DEI) initiatives or other reasons that allegedly conflicted with Department priorities.The U.S. District Court for the District of Massachusetts issued a temporary restraining order (TRO) requiring the Department to restore the status quo and continue funding the grants. The Department appealed the TRO and requested a stay pending the resolution of the appeal.The United States Court of Appeals for the First Circuit reviewed the Department's motion for a stay. The court found that the Department's termination letters lacked specific reasons for the terminations, making it difficult for the recipients and the court to understand the basis for the decision. The court also noted that the Department had not filed an administrative record, which is necessary for judicial review.The court determined that the Department's actions were likely arbitrary and capricious under the Administrative Procedure Act (APA) because the termination letters did not provide a clear explanation and failed to consider the reliance interests of the grant recipients. The court also found that the Department had not demonstrated irreparable harm that would result from the TRO, while the grant recipients would suffer significant harm if the funding was cut off.The First Circuit denied the Department's motion for a stay pending appeal, allowing the TRO to remain in effect. The court emphasized the importance of the Department providing a reasoned explanation for its actions and considering the impact on the grant recipients. View "State of California v. US Department of Education" on Justia Law

The case involves the United States government alleging that Regeneron Pharmaceuticals violated the Anti-Kickback Statute (AKS) by covering copayments for patients prescribed Eylea, a drug used to treat wet age-related macular degeneration. The government contends that this action induced doctors to prescribe Eylea, leading to Medicare claims that were "false or fraudulent" under the False Claims Act (FCA) because they "resulted from" the AKS violation.The United States District Court for the District of Massachusetts reviewed the case and agreed with Regeneron's interpretation that the phrase "resulting from" in the 2010 amendment to the AKS requires a but-for causation standard. This means that the government must prove that the AKS violation was the actual cause of the Medicare claims. The district court noted the conflict in case law and sought interlocutory review, which was granted.The United States Court of Appeals for the First Circuit affirmed the district court's ruling. The court held that the phrase "resulting from" in the 2010 amendment to the AKS imposes a but-for causation requirement. The court reasoned that the ordinary meaning of "resulting from" requires actual causality, typically in the form of but-for causation, unless there are textual or contextual indications to the contrary. The court found no such indications in the 2010 amendment or its legislative history. Therefore, to establish falsity under the FCA based on an AKS violation, the government must prove that the kickback was a but-for cause of the submitted claim. View "United States v. Regeneron Pharmaceuticals, Inc." on Justia Law