Justia Government & Administrative Law Opinion Summaries

During a government shutdown that began on October 1, 2025, the United States Department of Agriculture (USDA) announced it would not provide November Supplemental Nutrition Assistance Program (SNAP) benefits, affecting millions of Americans who rely on these funds for food. Despite having approximately $6 billion in contingency funds appropriated by Congress for emergencies, USDA stated it would not use these funds, arguing they were unavailable once regular appropriations lapsed. Plaintiffs, including nonprofits, local governments, a union, and a food retailer, filed suit, alleging that USDA’s suspension of benefits was arbitrary, capricious, and contrary to law under the Administrative Procedure Act (APA).The United States District Court for the District of Rhode Island granted a temporary restraining order (TRO) requiring USDA to provide either full or partial November SNAP payments by specified dates. The government chose to provide partial payments but failed to do so in a timely manner, as many recipients would not receive benefits by the court’s deadline. The district court found the government had not complied with its order, both by failing to resolve administrative burdens and by not ensuring timely disbursement. As a result, the court ordered USDA to make full November SNAP payments, including by using funds from the Section 32 fund in combination with contingency funds. The government appealed and sought a stay of the district court’s order.The United States Court of Appeals for the First Circuit reviewed the government’s request for a stay pending appeal. The court held that the government had not met its burden to justify a stay, finding it had failed to show a likelihood of success on the merits or that irreparable harm would result from compliance. The court emphasized the immediate and substantial harm to SNAP recipients if benefits were withheld and denied the government’s motion for a stay. View "Rhode Island State Council of Churches v. Rollins" on Justia Law

The case concerns multiple petitions for review challenging a Federal Communications Commission (FCC) order that established new rate caps for communications services provided to incarcerated individuals. The FCC’s order, issued pursuant to the Martha Wright-Reed Just and Reasonable Communications Act of 2022, also dismissed as moot certain petitions for clarification and waiver filed by Securus Technologies, LLC, a provider of these services. After the FCC published portions of the order in the Federal Register, several parties—including service providers, advocacy organizations, and state governments—filed petitions for review in various federal appellate courts, contesting different aspects of the order.Following the filing of these petitions, the FCC notified the United States Judicial Panel on Multidistrict Litigation (JPML) under 28 U.S.C. § 2112(a)(3), which randomly selected the United States Court of Appeals for the First Circuit to hear the consolidated petitions. The administrative record was filed in the First Circuit, and subsequent petitions filed in other circuits were transferred there pursuant to statute. Some petitioners, notably Securus and Pay Tel Communications, Inc., argued that the petitions should be transferred to the Fifth Circuit, asserting that it was the proper venue based on the timing and nature of the initial filings. The First Circuit denied these transfer motions, and a request for mandamus to the Supreme Court was also denied.The United States Court of Appeals for the First Circuit held that the petitions for review are properly before it, as the administrative record was filed there pursuant to the JPML’s direction. The court rejected arguments for mandatory transfer to the Fifth Circuit, finding no legal basis to override the JPML’s selection or to collaterally attack its determination. The court also declined to exercise its discretion to transfer the petitions elsewhere. View "Direct Action for Rights and Equality v. Federal Communications Commission" on Justia Law

Residents and the municipality of Morovis, Puerto Rico, brought suit against the Puerto Rico Aqueduct and Sewer Authority (PRASA) and its officials, alleging that for years, Morovis has suffered from a severe water crisis, with many residents lacking water service on most days. The plaintiffs, all PRASA subscribers, claimed that despite repeated notifications and proposed solutions—including a report from the U.S. Army Corps of Engineers—PRASA failed to address the crisis. They alleged that sometimes the outages could be resolved by simply turning on pumps or generators, and that PRASA officials were aware of the situation but did little to provide alternative water sources or adjust billing. The plaintiffs also recounted incidents suggesting deliberate inaction or sabotage by PRASA employees.The United States District Court for the District of Puerto Rico dismissed the case in its entirety at the pleading stage, concluding that the plaintiffs failed to state a claim for a substantive due process violation under the Fourteenth Amendment. The court found that the alleged conduct did not rise to the level of “shocking the conscience,” and also held that the plaintiffs’ contracts with PRASA could not form the basis of a substantive due process claim. The court did not decide whether Puerto Rico law created a protected property interest in water service.On appeal, the United States Court of Appeals for the First Circuit held that the district court erred in dismissing the substantive due process claim. The First Circuit ruled that the plaintiffs plausibly alleged government conduct that could shock the conscience, particularly under a deliberate indifference standard, given the prolonged and severe deprivation of water. The court vacated the district court’s dismissal and remanded for further proceedings, leaving unresolved whether a protected property interest exists and whether qualified immunity applies. View "Maldonado-Gonzalez v. Puerto Rico Aqueduct & Sewer Authority" on Justia Law

The case concerns challenges to Executive Order No. 14160, issued in January 2025, which seeks to deny birthright citizenship to children born in the United States after its effective date if their fathers are not U.S. citizens or lawful permanent residents and their mothers are either unlawfully or temporarily present in the country. Plaintiffs include individual immigrants, nonprofit organizations, and a coalition of states and local governments. They allege that the Executive Order violates the Citizenship Clause of the Fourteenth Amendment, 8 U.S.C. § 1401(a), the equal protection component of the Fifth Amendment, the Separation of Powers doctrine, and the Administrative Procedure Act. The plaintiffs seek declaratory and injunctive relief to prevent enforcement of the Order.The United States District Court for the District of Massachusetts granted preliminary injunctions to both sets of plaintiffs, finding they were “exceedingly likely” to succeed on their claims under the Citizenship Clause and § 1401(a). The injunctions barred federal agencies and officials from enforcing the Executive Order against the plaintiffs and, in the case brought by the states, issued a nationwide injunction to provide complete relief. The government appealed, challenging the plaintiffs’ standing, the scope of the injunctions, and the merits of the constitutional and statutory claims.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s findings that the plaintiffs have Article III standing and are likely to succeed on the merits. The First Circuit held that the Executive Order’s denial of birthright citizenship to children born in the United States under the specified circumstances violates both the Citizenship Clause of the Fourteenth Amendment and 8 U.S.C. § 1401(a), as interpreted by United States v. Wong Kim Ark and subsequent precedent. The court affirmed the preliminary injunctions in part, vacated them in part as to agency defendants, and remanded for further proceedings consistent with its opinion. View "Doe v. Trump" on Justia Law

A group of out-of-state pig farmers and a pork processor challenged a Massachusetts law that prohibits the use of certain confinement methods for breeding pigs (specifically, gestation crates) and bans the sale in Massachusetts of pork products derived from pigs confined in such a manner. The plaintiffs, who operate outside Massachusetts and use these confinement methods, argued that the law discriminates against out-of-state producers and is preempted by federal statutes. The law was enacted by ballot initiative and became enforceable after the Supreme Court’s decision in National Pork Producers Council v. Ross.The United States District Court for the District of Massachusetts dismissed most of the plaintiffs’ claims, including those based on the Privileges and Immunities Clause, preemption by the Federal Meat Inspection Act (FMIA) and the Packers and Stockyards Act (PSA), the Full Faith and Credit Clause, the Due Process Clause, and the Import-Export Clause. The court allowed the dormant Commerce Clause claim to proceed, but ultimately granted summary judgment against the plaintiffs on that claim as well, after severing a provision of the law that it found discriminatory (the “slaughterhouse exemption”). The court found that the remaining provisions of the law did not discriminate against out-of-state interests and did not impose a substantial burden on interstate commerce.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that the Massachusetts law does not discriminate against out-of-state producers in purpose or effect, does not impose a substantial burden on interstate commerce under the Pike balancing test, and is not preempted by the FMIA or PSA. The court also rejected the plaintiffs’ claims under the Privileges and Immunities Clause, Full Faith and Credit Clause, Due Process Clause, and Import-Export Clause. The court found no procedural error in the district court’s handling of the case. View "Triumph Foods, LLC v. Campbell" on Justia Law

Several individuals who had received grants of parole under programs established by the Department of Homeland Security (DHS) for nationals of Cuba, Haiti, Nicaragua, and Venezuela challenged the government’s decision to terminate those grants. The parole programs, created during the Biden Administration, allowed eligible individuals from these countries to enter the United States temporarily for up to two years, based on urgent humanitarian reasons or significant public benefit. When President Trump took office in January 2025, he issued executive orders directing DHS to end categorical parole programs, including the CHNV programs. DHS subsequently published a notice terminating the programs and revoking all existing grants of parole within thirty days, rather than allowing them to expire naturally.The plaintiffs, affected by the early termination, filed suit in the United States District Court for the District of Massachusetts. The district court certified a class of affected individuals and granted a preliminary stay, preventing DHS from revoking their parole grants before the original expiration dates. The court found that the plaintiffs were likely to succeed on their claim that the categorical termination was arbitrary and capricious under the Administrative Procedure Act (APA), in part because the agency’s rationale rested on a legal error and failed to adequately consider reliance and humanitarian interests.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s order. The First Circuit held that the relevant statute requires DHS to grant parole only on a case-by-case basis, but does not impose the same limitation on the termination of parole. The court also found that the agency’s explanation for terminating the parole programs was not so deficient as to be arbitrary and capricious under the APA. Concluding that the plaintiffs had not made a strong showing of likelihood of success on the merits, the First Circuit vacated the district court’s stay and remanded for further proceedings. View "Doe v. Noem" on Justia Law

In March 2025, the President issued an executive order directing federal officials to eliminate non-statutory functions and reduce statutory functions of three federal agencies: the Institute of Museum and Library Services (IMLS), the Minority Business Development Agency (MBDA), and the Federal Mediation and Conciliation Service (FMCS). These agencies, established and funded by Congress, provide grants and services to states and other entities. Following the executive order, the agencies terminated, reassigned, or placed on leave nearly all employees and canceled numerous grants, which plaintiffs—twenty-one states—alleged caused immediate and ongoing harm, including loss of services, forced layoffs, and canceled programming.The United States District Court for the District of Rhode Island granted a preliminary injunction, finding that the plaintiffs had suffered and would continue to suffer concrete injuries due to the agencies’ actions. The court determined that the agencies’ actions likely violated the Administrative Procedure Act and constitutional provisions, including the Take Care Clause and separation of powers. The injunction barred implementation of the executive order as to the three agencies, required reversal of actions taken to implement the order, restoration of employees, and resumption of grant funding, while allowing for efficiency measures not motivated by the executive order. The district court denied the government’s request for a stay of the injunction pending appeal.The United States Court of Appeals for the First Circuit reviewed only the government’s motion for a stay pending appeal. The court denied the stay, holding that the government failed to make a strong showing of likely success on the merits, particularly because it did not adequately challenge the district court’s constitutional analysis and had not preserved certain arguments. The court also found that the balance of harms and public interest did not favor a stay. View "Rhode Island v. Trump" on Justia Law

Angel A. Perales-Muñoz was hired as a recruiter assistant by Document and Packaging Brokers, Inc. (Docupak), a contractor for the National Guard Bureau, to help recruit individuals for the Army National Guard. The Army Criminal Investigation Division (CID) began investigating possible fraud in the recruiting program, which led to Perales being indicted on multiple federal charges related to conspiracy and fraud. After two years, the government moved to dismiss the charges against Perales, and the indictments were dismissed with prejudice. Perales and his wife subsequently filed administrative claims and then a lawsuit under the Federal Tort Claims Act (FTCA), alleging that the CID’s investigation was negligent and caused them emotional distress.The United States District Court for the District of Puerto Rico reviewed the case. The government moved to dismiss, arguing that the discretionary function exception to the FTCA barred the claims, as the investigation involved policy discretion. The district court ordered limited jurisdictional discovery and referred the matter to a magistrate judge, who found that the CID’s investigation did not violate the Posse Comitatus Act or Army Regulation 195-2. The district court adopted the magistrate’s report and recommendation, dismissing the complaint for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s dismissal de novo. The appellate court held that the discretionary function exception applied because Perales failed to show that the CID’s investigation violated any binding federal law or regulation. The court found no violation of the Posse Comitatus Act or Army Regulation 195-2 and concluded that federal courts lacked jurisdiction over the claims. The judgment of the district court was affirmed. View "Perales-Munoz v. United States" on Justia Law

Two brothers with developmental disabilities, Gaven and Jared, live with their parents, who are certified to provide in-home care. Both brothers qualified for Maine’s “Single Member Services,” which would allow each to receive one-on-one care from a designated provider. The family requested that each parent be reimbursed for providing care to one brother. However, the Maine Department of Health and Human Services determined that, because the brothers lived together, they were only eligible for “Two Member Services,” meaning a single provider would be reimbursed to care for both, at half the total rate. The parents continued to provide one-on-one care to both brothers, but were only reimbursed for one provider, resulting in a significant financial shortfall.The family challenged this determination in Maine Superior Court, which ruled in their favor, finding that the Department’s interpretation of its rules was arbitrary and inconsistent with its policies. Following this decision, the Department began reimbursing both parents for providing one-on-one care. The family then filed a federal lawsuit seeking damages for the period before the state court’s ruling, alleging discrimination under Title II of the Americans with Disabilities Act (ADA). The United States District Court for the District of Maine dismissed the case, holding that the Department was protected by Eleventh Amendment sovereign immunity.On appeal, the United States Court of Appeals for the First Circuit reversed the district court’s dismissal. The First Circuit held that the Department was not entitled to sovereign immunity because Congress validly abrogated such immunity under Title II of the ADA in this context. The court found that the Department’s policy violated the brothers’ equal protection rights, as there was no rational basis for providing reduced services solely because the brothers lived together. The case was remanded for further proceedings. View "McKenna v. Maine Department of Health and Human Services" on Justia Law

A coastal town in Maine, known for its small population and proximity to a national park, experienced a significant increase in cruise ship tourism, with large vessels bringing thousands of passengers daily. In response to concerns about congestion, public safety, and the impact on local amenities, residents approved an ordinance capping the number of cruise ship passengers who could disembark in the town to 1,000 per day. The ordinance imposed fines for violations and was intended to address issues primarily at the waterfront and, to a lesser extent, in the downtown area.Several local businesses, a business association, and a pilots’ association challenged the ordinance in the United States District Court for the District of Maine. They argued that the ordinance was preempted by federal and state law, violated the Commerce Clause (including its dormant aspect), and infringed on due process rights. After a bench trial, the District Court largely ruled in favor of the town and an intervening resident, rejecting most claims but finding that the ordinance was preempted by federal regulations only to the extent it restricted crew members’ shore access. The court declined to enjoin the ordinance, noting the town’s intent to address this issue through further rulemaking.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rejection of the state law preemption, federal preemption (except for the now-moot crew access issue), and due process claims. The First Circuit also affirmed the dismissal of discrimination-based Dormant Commerce Clause claims, finding no similarly situated in-state and out-of-state competitors. However, the court vacated and remanded the District Court’s dismissal of the Pike balancing Dormant Commerce Clause claim, instructing further analysis of whether the ordinance’s burdens on interstate commerce are clearly excessive in relation to its local benefits. The court dismissed as moot the appeals related to the crew access issue. View "Ass'n to Preserve and Protect Local Livelihoods v. Town of Bar Harbor" on Justia Law