Justia Government & Administrative Law Opinion Summaries

The case involves Brandon Peterson, an inmate at Washington County Jail (WCJ), who filed a lawsuit alleging violations of his constitutional rights by various jail officials. The United States Court of Appeals for the Eighth Circuit, reviewing the case, had to decide on numerous instances of alleged excessive force, failure to intervene, and deliberate indifference to serious medical needs, as well as constitutional and state law claims.The court found that on several occasions of alleged excessive force, the officers' actions were justified given Peterson's disruptive and threatening behavior. Consequently, the court granted qualified immunity to the officers involved in these incidents. In the case of the failure to intervene claims, the court decided that without an underlying constitutional violation, there can be no liability for failure to intervene, resulting in the officers being granted qualified immunity for these claims as well.On the issue of deliberate indifference to Peterson's mental health condition, the court found that the prison officials had made efforts to address his condition and had not acted with deliberate disregard for his health. Therefore, the court reversed the district court's denial of qualified immunity to the officials involved.Regarding Peterson's claim of being subjected to unconstitutional conditions of confinement, the court remanded the case to the district court for it to address this issue. The court also remanded the case to the district court to decide on the state law and Monell claims. As such, the Appeals Court reversed in part, dismissed in part, and vacated in part the district court's decision, remanding the case for further proceedings consistent with the court’s opinion. View "Peterson v. Heinen" on Justia Law

In November 2020, Autumn Hilger visited the Mount Rushmore National Memorial and slipped on a temporary access mat that was installed due to renovations, which resulted in her breaking her wrist. Hilger filed a negligence claim against the United States Government under the Federal Tort Claims Act (FTCA), seeking $2 million for her injuries. The Government denied her claim, leading her to sue and allege that the National Park Service (NPS), a government agency, negligently installed and maintained the access mat and failed to warn of its danger. The district court dismissed her claims for lack of subject matter jurisdiction, applying the discretionary-function exception to the FTCA. Hilger appealed the dismissal.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court used a two-step test to determine whether the discretionary-function exception applies, first asking whether the challenged conduct or omission is discretionary, meaning it involves judgment or choice and is not controlled by mandatory statutes or regulations. Hilger had conceded in her appeal that there were no such controlling statutes or regulations, leading the court to agree with the district court that the challenged conduct was discretionary. The second inquiry was whether the judgment or choice was based on considerations of social, economic, and political policy. The court found that Hilger's complaint did not contain sufficient factual allegations to rebut the presumption that the discretion was grounded in policy considerations. The court concluded that the decisions regarding the mat were susceptible to policy analysis and that safety concerns, which Hilger argued were key in this case, are a typical policy consideration when applying the discretionary-function exception. As such, the court affirmed the district court's order dismissing Hilger's claims for lack of subject matter jurisdiction. View "Hilger v. United States" on Justia Law

The case involves Strategic Technology Institute, Inc. ("STI") and the National Labor Relations Board. STI had a contract to maintain engines and propellers for the U.S. Air Force from August 2017 until July 2020. During this time, STI's employees at a Little Rock facility began discussing unionizing. In response to this, Tyler Boyd of STI fired 17 employees — three on September 27, 2019, and fourteen on October 9, 2019. The administrative law judge and the Board found that these terminations violated subsections 8(a)(1) and (3) of the National Labor Relations Act, which prohibits employers from interfering with, restraining, or coercing employees in their right to engage in union activities and from discriminating in regard to hire or tenure of employment to encourage or discourage membership in any labor organization.STI petitioned for a review of the Board's order, and the United States Court of Appeals for the Eighth Circuit granted the petition, vacated the order, and remanded the case. The court found that there was no substantial evidence to support the Board's finding that the terminations were motivated by anti-union animus. The court noted that the only evidence of STI's knowledge of the union activities were two phone calls informing Tyler Boyd that the employees were considering unionizing and the timing of the firings. The court held that this was not sufficient to establish that STI acted with an anti-union motive when it terminated the employees. The court also found that the Board's reliance on the "small plant doctrine" to infer employer knowledge of union activity was not applicable in this case since there was no other evidence indicating a likelihood that Boyd knew of the union activities. Furthermore, the court held that the Board erred in finding that STI's reasons for the firings were pretextual because they were based on legitimate factors such as performance, attendance, and interpersonal skills. The court concluded that the General Counsel failed to meet its burden of providing substantial evidence that STI harbored anti-union animus and that the terminations were motivated by animus. Consequently, the court vacated the Board's order and remanded the case for proceedings consistent with its opinion. View "Strategic Technology Institute v. NLRB" on Justia Law

Facing a tight deadline from the Ninth Circuit, the Environmental Protection Agency banned the use of chlorpyrifos on food crops. Two environmental groups petitioned the EPA in 2007 to have all tolerances revoked. In denying the petition, the EPA concluded that their objections were “not supported by valid, complete, and reliable evidence.”   The Eighth Circuit granted the petitions, finding that the EPA’s decision was arbitrary and capricious. The court explained that in this case, the EPA believed it lacked discretion or at least acted that way. The Ninth Circuit’s opinion had already narrowed its options down to two: revoke the tolerances or modify them. With little time to act, the agency ruled out the second option, leaving only revocation by default. In doing so, however, it misread the statute and misunderstood the “scope of its discretion”. Therefore, the court set aside the decision as arbitrary and capricious. Further, the court explained that a partial ban was a real alternative for the EPA. It could have canceled some registrations and retained others that satisfied the statutory safety margin. View "RRVSG Assoc. v. Michael Regan" on Justia Law

Debt collector Rent Recovery Solutions (“RRS”) called Plaintiff to collect an alleged $900 debt to her former landlord. In June, without sending the relevant documents to Plaintiff, RRS reported her debt to TransUnion, a credit reporting agency, failing to tell TransUnion that the debt was disputed. Plaintiff commenced this action against RRS, alleging that it violated the Fair Debt Collection Practices Act (“FDCPA”). Plaintiff requested an award of $18,810 in attorneys’ fees for work by two attorneys and a paralegal. RRS challenged the fees requested by both attorneys, who submitted sworn declarations and detailed billing records. The district court, applying the lodestar method of calculating an attorney fee award, found that the attorneys’ claimed hourly rates were reasonable, but the hours expended on the case were excessive. The court reduced the claimed attorney hours by fifty percent, exclusive of paralegal work, and awarded Plaintiff $9,480 in attorneys’ fees. Plaintiff’s attorneys accused the district court of departing from the lodestar calculation by imposing a “cap” that violates FDCPA policies and deprives counsel of full compensation for bringing consumer enforcement actions under this complex federal statute.   The Eighth Circuit affirmed. The court explained that the district court followed the lodestar method, reducing the award based on its determination of the number of attorney hours reasonably expended on litigation. There is a “strong presumption” that the lodestar method represents a reasonable fee. The court wrote that the district court did not abuse its substantial discretion in finding that fifty hours was unreasonable for such a claim. View "Adrianna Beckler v. Rent Recovery Solutions, LLC" on Justia Law

Parents Defending Education, an association of parents, brought this action to challenge a policy adopted by the Linn Mar Community School District in Iowa. The disputed policy is entitled “Administrative Regulations Regarding Transgender and Students Nonconforming to Gender Role Stereotypes.” The policy sets forth regulations for the District that “address the needs of transgender students, gender-expansive students, nonbinary, gender nonconforming students, and students questioning their gender to ensure a safe, affirming, and healthy school environment where every student can learn effectively.” The parents who seek to participate in this case are anonymous; the pleadings identify them by a letter of the alphabet. The district court determined that Parents Defending failed to establish Article III standing because the organization did not show injury, causation, or redressability on its claims.   The Eighth Circuit dismissed the appeal in part as moot and reversed on one claim. The court concluded that at least Parent G has alleged an injury in fact sufficient to confer Article III standing. Parent G asserts that her son wants to “state his belief that biological sex is immutable.” Because of the policy, however, Parent G states that her son remains silent in school “when gender identity topics arise” to avoid violating the policy. This student’s proposed activity “concerns political speech” and is “arguably affected with a constitutional interest.” Thus, Parent G has standing to bring a claim challenging the policy based on the First Amendment. Therefore, Parents Defending has standing as an association to pursue the claim on behalf of a member. View "Parents Defending Education v. LinnMar Community School Dist., et al" on Justia Law

Kenneth Kraemer and Kraemer Farms, LLC (collectively, “Plaintiffs”) commenced this qui tam action under the False Claims Act (“FCA”), against United Dairies, other dairy farms, and their partners and agents (“Defendants”) alleging that they knowingly filed false crop insurance claims. Plaintiffs’ FCA Complaint alleged that Defendants (1) fraudulently obtained crop insurance payments by falsely reporting a silage-use-only variety of corn as grain and using that false statement to obtain the payments, and (2) were unjustly enriched by receiving the payments. The district court held that Defendants submitted materially false claims but denied Plaintiffs FCA relief because they failed to prove that Defendants knowingly defrauded the United States. However, the court found that certain Defendants had been unjustly enriched and awarded damages to the United States. The United States then filed a post-trial motion urging the district court to vacate or amend its judgment because Plaintiffs do not have standing to seek common law unjust enrichment relief on behalf of the United States. The district court granted the motion and vacated its judgment for lack of subject matter jurisdiction.   The Eighth Circuit affirmed. The court explained that the dismissal of Plaintiffs’ FCA claims must be affirmed even if Plaintiffs are correct that the district court erred in ruling that any violations were not knowing. The court wrote that because it concludes that Defendants in submitting Acreage Reporting Forms supporting their crop insurance applications did not submit materially false claims for crop insurance payments, Plaintiffs contention -the district court applied the wrong legal standard in denying FCA relief on other grounds is of no moment. View "United States ex rel. Kenneth Kraemer v. United Dairies, L.L.P." on Justia Law

Great River Entertainment, LLC sought coverage from Zurich American Insurance for losses related to the COVID-19 pandemic. The district court granted Zurich’s motion to dismiss for failure to state a claim. Great River appealed and moved to remand because there was not complete diversity of citizenship.   The Eighth Circuit remanded to the district court to consider whether there is federal diversity jurisdiction. The court explained that it cannot proceed without subject matter jurisdiction. The court wrote that based on Great River’s new affidavit, it is unable to conclude that its members were diverse. While Great River’s carelessness has clearly wasted judicial resources, the court explained that it cannot address the merits before determining federal jurisdiction. This is a task better suited for the district court. The court wrote that on remand, the court may also take additional action it deems appropriate. View "Great River Entertainment, LLC v. Zurich American Insurance Co." on Justia Law

The City of Belle Plaine, Minnesota, designated Veterans Memorial Park as a limited public forum and granted permits to two groups to place monuments there. Before the Satanic Temple could place its monument, the City closed the Park as a limited public forum and terminated both permits. The Satanic Temple sued the City. The district court dismissed its claims, except for promissory estoppel. When the Satanic Temple moved to amend its complaint, a Magistrate Judg2denied its motion. The Satanic Temple filed a second suit, reasserting the dismissed claims and adding new ones. The district court held that res judicata bars the second suit and granted summary judgment to the City on the promissory estoppel claim from the first suit.   The Eighth Circuit affirmed. The court explained that the Satanic Temple failed to plausibly allege that closing the Park as a limited public forum was unreasonable or viewpoint discriminatory. The court further explained that the Satanic Temple asserted that the City violated its free exercise rights. The court explained that although the Enacting and Recession Resolutions were facially neutral, facial neutrality is not a safe harbor if the City’s actions targeted the Satanic Temple’s religious conduct. However, the Satanic Temple failed to plausibly claim that its display was targeted. Moreover, the Satanic Temple has not plausibly alleged that it and the Veterans Club were similarly situated or that it was treated differently. The City gave a permit to both groups, had no control over the fact that the Veterans Club placed its statue first, and closed the Park as a limited public forum to everyone. View "The Satanic Temple v. City of Belle Plaine" on Justia Law

Two organizations, one individual, one business (collectively “Private Plaintiffs”) and seventeen states (“the States”) sued the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) for overstepping its statutory authority and for violating federal law in promulgating the “Definition of ‘Frame or Receiver’ and Identification of Firearms” (“Final Rule”). Plaintiffs appealed the district court’s denial of a motion for a preliminary injunction.   The Eighth Circuit affirmed. The court explained that Plaintiffs have not clearly shown how the Final Rule will prevent them from engaging in constitutionally protected conduct. Regarding the business plaintiff in this case, we are left unsure what behavior it wishes to engage in, as an LLC, that is protected by the Second Amendment. Plaintiffs also argued they will suffer economic harm without a preliminary injunction. Plaintiffs asserted generally that compliance costs and uncertainty surrounding the validity and scope of the Final Rule will be costly to businesses and lead to fewer sales of firearms. However, Plaintiffs do not explain the economic harm in definite enough terms to show the extent of any harm is “actual and not theoretical.” The district court did not abuse its discretion in concluding Plaintiffs have not met their burden. View "Morehouse Enterprises, LLC v. Bureau of ATF" on Justia Law