Justia Government & Administrative Law Opinion Summaries

A non-profit organization, Citizens for Constitutional Integrity, sued the Census Bureau, the Department of Commerce, and related officials, alleging that the Bureau failed to proportionately reduce the basis of representation for states in the 2020 Census as required by the Fourteenth Amendment's Reduction Clause. Citizens claimed this failure diluted the voting power of its members in New York, Pennsylvania, and Virginia. The organization sought relief under the Administrative Procedure Act (APA) and a writ of mandamus.The United States District Court for the District of Columbia dismissed the case for lack of standing. The court found that Citizens could not demonstrate that its alleged vote dilution injury was traceable to the Bureau's actions. Specifically, the court noted that Citizens failed to show how the Bureau's failure to apply the Reduction Clause directly caused the loss of congressional representation for the states in question. The court also found the data scientist's declaration provided by Citizens unpersuasive, as it did not adequately account for the number of disenfranchised voters in the relevant states.The United States Court of Appeals for the District of Columbia Circuit affirmed the District Court's dismissal. The appellate court held that Citizens did not establish traceability under Article III standards. The court found that Citizens failed to present a feasible alternative methodology for apportionment that would have resulted in a different allocation of seats for New York, Pennsylvania, and Virginia. The court also rejected Citizens's argument that it was entitled to a relaxed standing requirement for procedural-rights cases, concluding that the challenge was substantive rather than procedural. Consequently, the court affirmed the District Court's ruling that Citizens lacked standing to pursue its claims. View "Citizens for Constitutional Integrity v. Census Bureau" on Justia Law

K.N., an eight-year-old boy with multiple disabilities, lives in a non-wheelchair-accessible apartment in the District of Columbia. His mother, Margda Pierre-Noel, requested that the District and his school, Bridges Public Charter School, provide assistance to move K.N. from their apartment door to the school bus. The District denied the request, citing its policy that staff only retrieve students from the outermost door of their dwelling and do not physically lift or carry students.The Office of the State Superintendent of Education (OSSE) hearing officer ruled that it was beyond his authority to order the requested assistance but required OSSE to offer transportation services to and from the outer door of K.N.'s apartment building. Pierre-Noel then filed a lawsuit in the United States District Court for the District of Columbia, which granted summary judgment in favor of the District, ruling that the service requested was not a transportation service under the Individuals with Disabilities Education Act (IDEA).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the IDEA requires the District to provide door-to-door transportation services for K.N., as such services are necessary for him to benefit from his special education. The court found that the term "transportation" under the IDEA includes moving a child from their apartment door to the vehicle that will take them to school. The court vacated the district court's grant of summary judgment and remanded the case for further proceedings consistent with its opinion. The appeal was dismissed as moot with respect to Bridges Public Charter School, as K.N. was no longer enrolled there. View "Pierre-Noel v. Bridges Public Charter School" on Justia Law

Lake Region Healthcare Corporation operates a hospital in Minnesota and experienced a significant decrease in Medicare inpatient discharges in 2013, qualifying it for a volume-decrease adjustment (VDA). The hospital sought an adjustment of $1,947,967 using a method that estimates the portion of Medicare payments attributable to fixed costs. A Medicare contractor denied the adjustment, applying a method that treats all Medicare payments as compensation for fixed costs, resulting in no adjustment. The Provider Reimbursement Review Board (PRRB) reversed the contractor's decision, but the Centers for Medicare & Medicaid Services (CMS) reinstated it.The United States District Court for the District of Columbia ruled in favor of the government, deferring to CMS's method under Chevron deference. The court found that the statute did not specify how to calculate the VDA and that CMS's method was a reasonable interpretation, even if not the best one. The court concluded that CMS's approach was consistent with the statutory requirement to compensate only for fixed costs.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that CMS's method of attributing all Medicare payments to fixed costs did not comply with the statutory requirement to fully compensate hospitals for their fixed costs. The court noted that Medicare payments cover both fixed and variable costs and that CMS's method overstates the amount of reimbursed fixed costs, thus understating unreimbursed fixed costs. The court found that reasonable proxies exist to estimate the fixed-cost component of Medicare payments and that CMS's method was not a reasonable approximation of full compensation for fixed costs.The court reversed the district court's decision, granted summary judgment to Lake Region, and remanded the case to the agency for further proceedings consistent with the opinion. View "Lake Region Healthcare Corporation v. Becerra" on Justia Law

Four aliens who were denied asylum and an organization assisting them filed FOIA requests for copies of the aliens’ Assessments to Refer and associated documents. USCIS released the factual portions of the Assessments but withheld portions containing analysis by the asylum officers, including opinions, deliberations, and recommendations regarding each applicant’s eligibility for asylum. The plaintiffs sued to obtain the full Assessments.The United States District Court for the District of Columbia granted summary judgment to the government. It held that the deliberative-process privilege covers the requested Assessments and that USCIS had adequately shown that releasing the withheld portions would foreseeably harm USCIS’s interest in receiving candid recommendations from its asylum officers. After the plaintiffs appealed, the case was remanded for further consideration in light of a new decision, Reporters Committee for Freedom of the Press v. FBI. On remand, USCIS submitted a supplemental declaration elaborating on the agency’s assessment of foreseeable harm, and the district court again granted summary judgment to DHS.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the deliberative-process privilege applies to the four requested Assessments and that DHS adequately showed that disclosure of their analysis portions would foreseeably harm interests the privilege protects. The court found that the supplemental declaration provided by USCIS’s Chief FOIA Officer sufficiently demonstrated foreseeable harm by explaining the sensitive nature of asylum adjudications and the specific concern about facilitating asylum fraud. The court affirmed the summary judgment for DHS. View "Emuwa v. DHS" on Justia Law

The case involves the U.S. Sugar Corporation and other industry petitioners challenging the Environmental Protection Agency's (EPA) 2022 rule that classified certain industrial boilers as "new" sources of hazardous air pollutants, even though they were built before the applicable emission standards were proposed in 2020. The EPA used a 2013-era dataset to establish these standards, excluding more recent data to maintain consistency with still-valid 2013 standards. Environmental petitioners argued that this exclusion violated the Clean Air Act.The U.S. Court of Appeals for the District of Columbia Circuit reviewed the case. The lower court had previously remanded the EPA's 2011 rule without vacatur, allowing the invalid standards to remain while the EPA revised them. The industry petitioners argued that the EPA's classification of boilers built after June 4, 2010, as "new" sources was incorrect, as these boilers were constructed before the 2020 proposal of the new standards. The environmental petitioners contended that the EPA's decision to use outdated data was arbitrary and capricious.The D.C. Circuit held that the EPA's classification of boilers built before August 24, 2020, as "new" sources was incorrect under the Clean Air Act. The court found that the proper date to determine whether a boiler is "new" should be when each specific emission standard is first proposed, not when any standard for the category was first proposed. Therefore, the court set aside the EPA's 2022 rule to the extent that it defined sources constructed before August 24, 2020, as "new."The court also held that the EPA's decision to rely on the 2013-era dataset was neither unlawful nor arbitrary and capricious. The court found that the EPA's choice was reasonable given the limited nature of the remand and the need for consistency across standards. Thus, the court denied the environmental petitioners' petition for review. View "United States Sugar Corporation v. EPA" on Justia Law

Holtec International applied to the Nuclear Regulatory Commission (NRC) for a license to construct and operate a spent nuclear fuel storage facility in New Mexico. The NRC denied multiple requests for intervention and a hearing from various petitioners, including Beyond Nuclear, Sierra Club, and Fasken Land and Minerals. These petitioners argued that the NRC acted unreasonably and contrary to law in denying their requests.The Atomic Safety and Licensing Board (Board) found the petitioners' contentions inadmissible and denied their petitions to intervene. The NRC affirmed the Board’s decisions. Beyond Nuclear, Environmental Petitioners (including Sierra Club), and Fasken each petitioned for review of the orders denying intervention. The case was held in abeyance until the NRC issued Holtec a license, after which the case was removed from abeyance for review by the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit reviewed the petitions and found that the NRC reasonably declined to admit the petitioners' factual contentions and complied with statutory and regulatory requirements. The court held that Beyond Nuclear did not raise a genuine dispute of law or fact regarding the NRC’s authority to consider Holtec’s application. The court also found that Environmental Petitioners failed to demonstrate any genuine disputes of material fact or law in their contentions related to statutory authority, alleged misrepresentations by Holtec, and compliance with the National Environmental Policy Act (NEPA). Additionally, the court determined that Fasken’s late-filed contentions were procedurally defective, untimely, and immaterial.The court denied all the petitions for review, affirming the NRC’s decisions to deny the requests for intervention. View "Beyond Nuclear, Inc. v. NRC" on Justia Law

Pacific Gas and Electric Company (PG&E) and the San Francisco Public Utilities Commission (SFPUC) have a longstanding dispute over PG&E's obligation to wheel energy to SFPUC's customers. SFPUC generates power and sells it to end users in San Francisco but relies on PG&E to distribute this energy. The disagreement centers on which consumers are entitled to wheeled service under a grandfathering clause in PG&E's 2015 Tariff, which incorporates a statutory provision allowing wheeling for consumers served by SFPUC as of October 24, 1992.Initially, the Federal Energy Regulatory Commission (FERC) rejected SFPUC's class-based approach, which argued that PG&E should wheel energy to the same types of customers served in 1992. FERC's 2019 order was vacated by the United States Court of Appeals for the District of Columbia Circuit, which remanded the case for FERC to provide a reasoned analysis of the statutory requirements. On remand, FERC adopted a class-based interpretation, allowing wheeling to all customers of the same class served in 1992, not just specific end users.The United States Court of Appeals for the District of Columbia Circuit reviewed FERC's orders and found them contrary to law. The court held that the plain meaning of "ultimate consumer" in the statutory provision refers to specific end users, not classes of consumers. The court emphasized that the statutory text does not support a class-based interpretation and that such an interpretation would undermine the primary restriction against FERC-ordered wheeling. Consequently, the court vacated FERC's orders and remanded the case for FERC to apply the plain meaning of the statute and determine which of SFPUC's consumers qualify for wheeled service under the 2015 Tariff. View "Pacific Gas and Electric Company v. FERC" on Justia Law

United Parcel Service, Inc. (UPS) challenged the Postal Regulatory Commission's (Commission) handling of the United States Postal Service's (Postal Service) pricing of competitive products, arguing that the Postal Service underprices these products by not accounting for "peak-season" costs incurred during the holiday season. UPS claimed that these costs, driven by increased demand for package deliveries, should be attributed to competitive products rather than being treated as institutional costs.The Commission denied UPS's petition to initiate rulemaking proceedings and its subsequent motion for reconsideration. The Commission found that UPS's methodology for calculating peak-season costs was flawed and did not produce reliable estimates. It also concluded that the existing cost-attribution framework already accounted for the costs caused by competitive products during the peak season. The Commission explained that the Postal Service's costing models, which use an incremental-cost approach, appropriately attribute costs to competitive products and that the remaining costs are correctly treated as institutional costs.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld the Commission's decision, finding that the Commission's rejection of UPS's methodology was reasonable and well-explained. The court noted that the Commission had addressed UPS's concerns about the Postal Service's costing models and had initiated further proceedings to explore potential updates to the models. The court also rejected UPS's argument that the Commission failed to consider whether peak-season costs are institutional costs uniquely associated with competitive products, noting that this issue was not properly presented in this case.The court denied UPS's petition for review, affirming the Commission's orders. View "United Parcel Service, Inc. v. PRC" on Justia Law

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued new and revised safety standards for pipelines in 2022. The Interstate Natural Gas Association of America (INGAA), representing pipeline companies, challenged five of these standards, arguing that PHMSA failed to justify the benefits outweighing the costs as required by law.The U.S. Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that four of the five challenged standards were inadequately justified. Specifically, PHMSA failed to properly analyze the costs associated with the high-frequency electric resistance welding (ERW) standard, the crack maximum allowable operating pressure (MAOP) standard, the dent-safety-factor standard, and the corrosive-constituent standard. The court noted that PHMSA either did not recognize new costs imposed by these standards or provided inconsistent explanations regarding the costs.The court vacated the high-frequency-ERW standard as applied to seams formed by high-frequency ERW, the crack-MAOP standard, the dent-safety-factor standard and related provisions, and the corrosive-constituent standard. The court also vacated the high-frequency-ERW standard but only as applied to seams formed by high-frequency ERW.However, the court upheld the pipeline-segment standard. INGAA had argued that a change in terminology from "SCC segment" to "covered pipeline segment" would significantly increase the number of required excavations. PHMSA clarified that there was no substantive difference between the proposed and final versions of the rule. The court accepted PHMSA's explanation and found no basis to challenge the cost-benefit analysis for this standard.In summary, the court granted INGAA's petition in part, vacating several standards due to inadequate cost-benefit analyses, but denied the petition regarding the pipeline-segment standard. View "Interstate Natural Gas Association of America v. PHMSA" on Justia Law

A collection of Dutch and Luxembourgish energy companies invested in solar power projects in Spain, relying on promised economic subsidies. Following the 2008 financial crisis, Spain withdrew these subsidies, prompting the companies to challenge Spain's actions through arbitration under the Energy Charter Treaty (ECT). The companies won multi-million-euro awards in arbitration. However, the European Union argued that the ECT's arbitration provision does not apply to disputes between EU Member States, rendering the awards invalid under EU law. The companies sought to enforce the awards in the United States, invoking the ICSID Convention and the New York Convention.The United States District Court for the District of Columbia reviewed the cases. In NextEra Energy Global Holdings B.V. v. Kingdom of Spain and 9REN Holding S.A.R.L. v. Kingdom of Spain, the court held it had jurisdiction under the Foreign Sovereign Immunities Act (FSIA) arbitration exception and denied Spain's motion to dismiss. The court also granted anti-anti-suit injunctions to prevent Spain from seeking anti-suit relief in foreign courts. Conversely, in Blasket Renewable Investments LLC v. Kingdom of Spain, the district court found Spain immune under the FSIA and dismissed the case, denying the requested injunction as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the cases. The court held that the district courts have jurisdiction under the FSIA’s arbitration exception to confirm the arbitration awards against Spain. However, it found that the district court in NextEra and 9REN abused its discretion by enjoining Spain from pursuing anti-suit relief in Dutch and Luxembourgish courts. The appellate court affirmed in part and reversed in part in NextEra, reversed in 9REN and Blasket, and remanded for further proceedings. View "NextEra Energy Global Holdings B.V. v. Kingdom of Spain" on Justia Law