Justia Government & Administrative Law Opinion Summaries

After Cody Franklin died in police custody, his father, as administrator of his estate, sued the police officers who struggled with Franklin the night he died, and against the municipalities who employed them. The elder Franklin asserted claims under 42 U.S.C. 1983 for excessive force, and claims under state law for battery and wrongful death. The district court entered summary judgment in favor of the municipalities and all but two of the officers. Those officers filed an interlocutory appeal, arguing they were entitled to qualified immunity on all claims. After review, the Eighth Circuit agreed with the officers with respect to the federal claims, and remanded. With respect to the state claims, the Court remanded for further proceedings, including a determination whether to exercise supplemental jurisdiction over those claims. View "Franklin v. Franklin County, Arkansas" on Justia Law

Marion Carter sued the Pulaski County Special School District for race discrimination under Arkansas state and federal laws. Carter taught at the Joe T. Robinson High School in the School District. She also coached the cheer and dance teams. In 2017, the school's principal recommended to the District Superintendent that Carter's cheer and dance duties not be renewed for the 2017-2018 school year, and that she be offered a teaching contract only. The principal cited: (1) lack of student participation in cheer and dance in the previous two years; (2) inappropriate cheer routines at sporting events; and (2) inappropriate behavior of cheerleaders during out-of-town travel. After a hearing, the District's School Board accepted the recommendation not to renew Carter's cheer and dance contract. The District filled the cheer position with an African-American woman, and eliminated all dance teams district-wide. The Eighth Circuit concurred with the district court's grant of summary judgment to the District on all claims. The Court found Carter's allegations were insufficient to defeat summary judgment. View "Carter v. Pulaski CO Special School Dist" on Justia Law

Plaintiffs, health care providers and their patients, filed suit against Iowa's Department of Public Health and its Health Facilities Council, alleging that Iowa's Certificate of Need laws violate the Fourteenth Amendment's Due Process, Equal Protection, and Privileges and Immunities Clauses.The Eighth Circuit held that plaintiffs' Privileges and Immunities Clause claim was foreclosed by the Slaughter-Houses cases. Applying rational basis review to the Certificate of Need (CON) regime and capital expenditures exemption, the court held that Iowa's CON requirement is rationally related to a legitimate state interest in full-service hospital viability. Furthermore, Iowa's decision to exempt competitors who are non-hospital CON-holders is rationally related to its interest in protecting the viability of full-service hospitals. Therefore, the court affirmed the district court's orders dismissing plaintiffs' Privileges and Immunities claim and granting summary judgment in favor of the state defendants on the remaining claims. View "Birchansky v. Clabaugh" on Justia Law

The Eighth Circuit granted a petition for review of the ARB's final decision ruling that CP violated the whistleblower retaliation provisions of the Federal Railroad Safety Act (FRSA) when it suspended a locomotive engineer for his untimely reporting of a "work-related personal injury" or a "hazardous safety or security condition." The court agreed with CP's argument that the ARB's analysis of the contributing factor element of the employee's prima facie case used a legal causation standard contrary to controlling Eighth Circuit precedents.The court held that the ARB's reasoning was both contrary to the court's governing precedents and fatally flawed; the FRSA prohibits a rail carrier from discriminating against an employee for engaging in protected activity; the employee does not have to conclusively prove retaliatory motive but must show more than temporal proximity between the protected activity and the adverse action; and the court expressly rejected the contention that, when an employer learns about an employee's conduct warranting discipline in a protected injury report, the report and the discipline are "inextricably intertwined" and this factual connection is "sufficient to establish the contributing-factor element of his prima facie case." Because the ARB did not attempt to apply the appropriate Eighth Circuit legal standard, the court remanded to the ARB with instructions. View "Dakota, Minnesota & Eastern Railroad Corp. v. U.S. Department of Labor Administrative Review Board" on Justia Law

MHA filed suit challenging the part of DSH's 2017 Rule defining "costs incurred" as "costs net of third-party payments, including, but not limited to, payments by Medicare and private insurance." The Eighth Circuit reversed the district court's grant of summary judgment for MHA, holding that the statute did not delegate to the Secretary unfettered discretion to determine "costs incurred;" the terms "costs incurred" and "net of payments" have plain, unambiguous meanings; and MHA's interpretation of "costs" and "payments" was not plainly mandated by the structure of the statute. Therefore, the court held that the Secretary's interpretation was reasonable in light of the statute's purpose and design. Under Missouri's plan, the court explained that the State redistributes overpayments above a particular hospital's DSH annual limit proportionately among other DSH hospitals that are below their hospital-specific limits, redistributions that should benefit the most imperiled DSH members of the MHA. View "Missouri Hospital Assoc. v. Azar" on Justia Law

Kearney sought judicial review of the Board's decision denying its application to participate in the Medicare program. Although the facility later received approval, the initial denial prevented Kearney from participating in Medicare and receiving reimbursements for 87 days during 2014.The Eighth Circuit held that the Board failed adequately to explain the legal standard that it applied in resolving Kearney's administrative appeal. In this case, the court was unable to discern what meaning the Board attributed to 42 U.S.C. 1395x(e)(1) and the definition of "hospital." Furthermore, without an adequate explanation for what time period the agency considered in determining whether Kearney was primarily engaged in providing care to inpatients, the court was unable to resolve whether the Board's decision correctly applied the relevant legal standards. Therefore, the court reversed the district court's grant of summary judgment to the Department and remanded with directions. View "Kearney Regional Medical Center, LLC v. US Department of Health and Human Services" on Justia Law

Suits over oil and gas leases on allotted trust lands are governed by federal law, not tribal law, and the tribal court lacks jurisdiction over the nonmember oil and gas companies. This appeal involved a dispute over the practice of flaring natural gas from oil wells, and at issue was the scope of Native American tribal court authority over nonmembers. The Eighth Circuit affirmed the district court's grant of a preliminary injunction enjoining the tribal court plaintiffs and tribal court judicial officials and held that the district court correctly rejected the tribal court officials' argument that this suit was barred by tribal sovereign immunity.The court also held that the district court did not abuse its discretion in granting the preliminary injunction because the oil and gas companies are likely to prevail on the merits. In this case, the district court correctly concluded that the oil and gas companies exhausted their tribal court remedies by moving to dismiss the case for lack of jurisdiction and appealing the issue to the MHA Nation Supreme Court; the district court correctly concluded that the tribal court lacked jurisdiction over the oil and gas companies; and the balance of the remaining preliminary injunction factors, along with the oil and gas companies' strong likelihood of success on the merits, showed that the district court did not abuse its discretion by granting the preliminary injunction. View "Kodiak Oil & Gas (USA) Inc. v. Burr" on Justia Law

Plaintiff, along with her late husband, filed suit challenging a city ordinance that requires at least fifty percent of their residential yard to contain turf grass. The Eighth Circuit affirmed plaintiff's substantive due process claim, but held that the district court was without jurisdiction to dismiss the Eighth Amendment claim on the merits. In this case, plaintiff's claim that the city's ordinance violated her due process rights was barred by the doctrine of res judicata. Furthermore, the Eighth Amendment claim was not ripe for review, because it is unknown whether the city will impose sanctions or, if sanctions are imposed, what they might be. View "Duffner v. City of St. Peters" on Justia Law

The Eighth Circuit reversed the district court's order granting summary judgment to the Metropolitan Council on LPA's claim that the Council violated the National Environmental Policy Act (NEPA) and other federal and state laws. In this case the Council is the sole defendant and LPA filed suit prior to a final agency action.The court held that the district court lacked jurisdiction to hear LPA's claim, because Eighth Circuit precedent expressly rejects the viability of a NEPA cause of action outside of the Administrative Procedure Act framework, especially when the only defendant is a state agency. Therefore, LPA has no cause of action through which it could state a plausible claim. The court remanded with instructions to dismiss the case. View "Lakes and Parks Alliance of Minneapolis v. The Metropolitan Council" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims challenging the city's ordinance based on lack of standing. The challenged ordinance made it unlawful for any person to own, possess, keep, exercise control over, maintain, harbor, transport or sell within the City of Sioux City, Iowa, any pit bull. In this case, plaintiff admitted that she does not currently own a dog because she and her fiance work full time and do not have the time to own a dog, but she intended to adopt a dog in the near future.The court held that, to the extent plaintiff sought prospective relief against future conduct, she failed to show that she owns a dog and does not live in the city. Furthermore, her intention to adopt a dog in the near future was uncertain and insufficient to confer standing. The court also held that plaintiff's past injuries did not grant her standing because she failed to demonstrate how her proposed relief redressed them. Finally, the district court did not abuse its discretion by declining to hold an evidentiary hearing prior to its sua sponte dismissal of plaintiff's claim. View "Myers v. Sioux City" on Justia Law