Justia Government & Administrative Law Opinion Summaries

The case involves Pueo Kai McGuire, who filed a 42 U.S.C. § 1983 action against the County of Hawai'i, the county prosecutor, and three deputy prosecutors, alleging violations of his constitutional rights, including malicious prosecution. The United States District Court for the District of Hawai'i certified a question to the Supreme Court of the State of Hawai'i to determine whether, under Hawai'i law, a county Prosecuting Attorney and/or Deputy Prosecuting Attorney acts on behalf of the county or the state when preparing to prosecute and/or prosecuting criminal violations of state law.The United States District Court for the District of Hawai'i reviewed the case and found the matter of whether county prosecutors act on behalf of the county or the state to be unsettled under Hawai'i law. Consequently, the court certified this question to the Supreme Court of the State of Hawai'i for clarification.The Supreme Court of the State of Hawai'i held that, under Hawai'i law, county prosecuting attorneys and their deputies act on behalf of the county when preparing to prosecute or prosecuting state law offenses. The court's decision was based on an analysis of the historical and current legal framework governing prosecutorial authority in Hawai'i, including the Hawai'i Constitution, state statutes, and county charters. The court emphasized that county prosecutors are primarily responsible for initiating and conducting criminal prosecutions within their county jurisdictions, with the state attorney general retaining only residual authority to intervene in compelling circumstances. The court declined to extend state sovereign immunity to county prosecutors, affirming that they are suable persons under 42 U.S.C. § 1983. View "McGuire v. County of Hawai'i" on Justia Law

An off-duty St. Louis Police Officer, Milton Green, was mistakenly shot by Officer Christopher Tanner during a pursuit of a suspect who had fired at police officers. Green filed a lawsuit under 42 U.S.C. § 1983 against Tanner and the City of St. Louis, alleging Fourth and Fourteenth Amendment violations and state law claims. The district court granted summary judgment in favor of the defendants, concluding that Tanner did not violate Green’s constitutional rights and that official immunity barred the state-law claims. The court also denied Green’s motions to alter or amend the judgment and to submit newly discovered evidence.The United States District Court for the Eastern District of Missouri granted summary judgment to the defendants, finding that Tanner’s actions were reasonable under the circumstances and that there was no constitutional violation. The court also ruled that Green’s Monell claim against the City failed due to the lack of an underlying constitutional violation and that official immunity protected Tanner from the state-law claims. Green’s motions to alter or amend the judgment and to reopen discovery were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that Tanner’s use of force was objectively reasonable given the circumstances, which involved a rapidly evolving and dangerous situation. The court also upheld the dismissal of the Monell claims against the City, as there was no constitutional violation by Tanner. Additionally, the court affirmed the denial of Green’s post-judgment motions and the dismissal of the state-law battery claims, agreeing that official immunity applied. View "Green v. City of St. Louis" on Justia Law

Clarios, LLC (Clarios) purchased an industrial site in 2006, for which the seller had executed a remediation plan under the Industrial Site Recovery Act (ISRA) and placed funds in trust for future remediation. In 2007, Clarios ceased operations and sought a Remediation in Progress Waiver (RIP Waiver) from the New Jersey Department of Environmental Protection (DEP), which was granted with the condition that the DEP reserved the right to enforce ISRA obligations in the future. Clarios sold the site in 2011, and the new owner, DeNovo, assumed remediation responsibilities. By 2021, the remediation trust was depleted, and the site was out of compliance. In April 2022, the DEP rescinded Clarios’s RIP Waiver due to non-compliance and depletion of funds.Clarios requested an adjudicatory hearing, arguing that the rescission without notice or a hearing violated its due process rights. The DEP denied the request, stating that rescission did not entitle Clarios to a hearing under the relevant regulations. Clarios appealed, and the Appellate Division ruled in favor of the DEP, holding that Clarios did not have a protected property interest in the RIP Waiver. The court found that Clarios’s expectation of continued suspension of remediation obligations was not based on any statutory or regulatory provisions but rather on a unilateral expectation.The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division’s decision. The Court held that the DEP’s initial grant of the RIP Waiver did not create a property interest in the continued suspension of Clarios’s remediation obligations. The Court found that neither the controlling statutes and regulations nor a mutually explicit understanding between the parties provided an entitlement to the indefinite continuance of the waiver. The governing laws and agency materials anticipated the DEP’s ability to enforce remediation obligations in the future, and thus, rescission of the RIP Waiver without a hearing did not violate Clarios’s due process rights. View "In re Appeal of the New Jersey Department of Environmental Protection's September 6, 2022 Denial of Request for Adjudicatory Hearing" on Justia Law

The United States District Court for the District of Massachusetts issued a temporary restraining order (TRO) on March 10, 2025, preventing the Government from terminating various education-related grants. The order also required the Government to pay past-due grant obligations and continue paying future obligations. The District Court concluded that the respondents were likely to succeed on the merits of their claims under the Administrative Procedure Act (APA).The Government filed an application to vacate the District Court's order on March 26, 2025, which was extended on March 24, 2025. The application was presented to Justice Jackson and referred to the Supreme Court. The Supreme Court noted that the District Court's order had characteristics of a preliminary injunction, making it appealable. The Government argued that the District Court lacked jurisdiction to order the payment of money under the APA, as the APA's waiver of sovereign immunity does not apply to claims seeking money damages or to orders enforcing contractual obligations to pay money.The Supreme Court of the United States granted the Government's application to stay the District Court's order pending the appeal in the United States Court of Appeals for the First Circuit and any subsequent petition for a writ of certiorari. The Court found that the respondents had not refuted the Government's claim that it would be unlikely to recover the grant funds once disbursed and that respondents would not suffer irreparable harm while the TRO is stayed. The stay will terminate automatically if certiorari is denied or upon the sending down of the judgment of the Supreme Court if certiorari is granted. The Chief Justice would have denied the application. View "Department of Education v. California" on Justia Law

The case involves a dispute over the Tennessee Department of Environment and Conservation’s (TDEC) issuance of a water quality certification to Tennessee Gas Pipeline Company (TGP) for the construction and operation of a 32-mile natural gas pipeline in Tennessee. The pipeline would cross over one hundred bodies of water and require drilling across rocky terrain. Environmental groups Sierra Club and Appalachian Voices argue that TDEC failed to properly assess TGP’s application and ensure that the pipeline would not cause significant environmental damage.The lower court, TDEC, issued the water quality certification to TGP, authorizing temporary and permanent impacts to various water bodies and wetlands. TDEC imposed several conditions on TGP to minimize environmental disruption, including selecting the least impactful trenching techniques and obtaining written authorization before using controlled blasting. Petitioners filed a timely Petition for Review in the United States Court of Appeals for the Sixth Circuit, arguing that TDEC’s issuance of the certification violated the Administrative Procedure Act (APA).The United States Court of Appeals for the Sixth Circuit reviewed the case and found that TDEC did not violate the APA. The court held that TDEC adequately evaluated the water quality certification application and reasonably explained its decision-making process regarding waterbody crossings, rock removal methodology, downstream sedimentation, trench excavation, and baseline conditions of waterbodies. The court concluded that TDEC’s actions were not arbitrary, capricious, or inconsistent with its regulations. Consequently, the court denied the Petition for Review. View "Sierra Club v. Tennessee Department of Environment and Conservation" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law

A retired teacher, Patsy Talley, received overpayments in her retirement benefits from the North Carolina Teachers’ and State Employees’ Retirement System (TSERS) for over eight years, totaling $86,173.93. When the overpayment was discovered, TSERS began reducing her monthly benefits to recoup the overpaid amount. Talley did not dispute the overpayment but argued that the recoupment process violated her due process rights because she was not provided a hearing before the reductions began.The United States District Court for the Eastern District of North Carolina dismissed all of Talley’s claims. The court held that her official capacity claims were barred by the Eleventh Amendment, her substantive due process claim failed because she received adequate post-deprivation process, and her equal protection claim did not allege a fundamental right or suspect class. The court also dismissed her individual capacity procedural due process claim, finding the defendants were entitled to qualified immunity. Additionally, the court denied Talley’s motion to amend her complaint to add new plaintiffs, citing procedural deficiencies and lack of good cause.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court agreed that the Eleventh Amendment barred the official capacity claims and that the individual capacity claims were barred by qualified immunity. The court found that Talley failed to state a substantive due process claim because she received adequate post-deprivation process and that her equal protection claim did not meet the rational basis review. The court also upheld the denial of her motion to amend the complaint, finding no abuse of discretion by the district court. View "Talley v. Folwell" on Justia Law

A mother, Aurora Regino, filed a complaint against the Chico Unified School District after the district began using her child's new preferred name and pronouns without informing her. Regino claimed that the district's policy, which allows students to be addressed by their preferred names and pronouns without parental notification, violated her substantive and procedural due process rights. She argued that the policy deprived her of her fundamental rights as a parent to make decisions concerning the care, custody, and control of her children.The United States District Court for the Eastern District of California dismissed Regino's complaint, reasoning that she failed to allege the existence of a fundamental right that was clearly established in existing precedent. The court applied a standard similar to that used in qualified immunity cases, requiring that the right be clearly established in existing law.The United States Court of Appeals for the Ninth Circuit vacated the district court's dismissal, holding that the district court applied erroneous legal standards to the substantive and procedural due process claims. The Ninth Circuit clarified that a plaintiff asserting a substantive due process claim does not need to show that existing precedent clearly establishes the asserted fundamental right. Instead, the critical inquiry is whether the asserted fundamental right is deeply rooted in the nation's history and tradition and implicit in the concept of ordered liberty. The Ninth Circuit remanded the case to the district court to conduct the proper analysis, including a careful formulation of the asserted fundamental right and an examination of whether it is deeply rooted in history and tradition.The Ninth Circuit also held that the district court erred in its analysis of Regino's procedural due process claim by requiring her to identify a fundamental right. Procedural due process protects all liberty interests derived from state law or the Due Process Clause itself. The case was remanded for further proceedings consistent with the Ninth Circuit's opinion. View "REGINO V. STALEY" on Justia Law

Sunnyside Park Utilities, Inc. (SPU) provides water and sewer services to commercial properties in Bonneville County, Idaho. Donald Sorrells, the owner of a lot in the Sunnyside Industrial & Professional Park, received a "Will Serve" letter from SPU in 2018, agreeing to provide water and sewer services based on his representation that he would install only two restrooms. However, Sorrells installed additional unauthorized water and sewer connections, leading to repeated excessive discharges into SPU's septic system. Despite multiple notices and requests for remediation from SPU, Sorrells failed to address the issues adequately, resulting in SPU seeking a declaratory judgment against him.The District Court of the Seventh Judicial District of Idaho found that Sorrells was a persistent violator of SPU's Sewer Rules and Regulations but determined that the Idaho Public Utilities Commission (IPUC) retained original jurisdiction over SPU's water system. The court denied SPU's requests for costs and attorney fees, leading to appeals from both parties.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the district court did not err in granting a declaratory judgment to SPU regarding Sorrells' violations of the sewer rules. However, it also upheld the district court's determination that the IPUC initially had jurisdiction over SPU's water system, as SPU had not established its nonprofit status at the time of filing. The court further affirmed the denial of attorney fees and costs to SPU, concluding that the Rules and Regulations did not expressly provide for such fees.On appeal, the Supreme Court declined to consider the merits of Sorrells' arguments due to his failure to comply with the Idaho Appellate Rules. The court also denied SPU's request for attorney fees and costs on appeal, as SPU did not prevail on its cross-appeal. View "Sunnyside Park Utilities, LLC v. Sorrells" on Justia Law

California collects a fee from in-state hospitals and uses the revenue, along with federal Medicaid funds, to provide subsidies to California hospitals serving Medicaid beneficiaries. Out-of-state hospitals near the California border, which sometimes serve California Medicaid beneficiaries but do not pay the fee, sought access to these subsidies. They argued that their exclusion violated the dormant Commerce Clause, the Equal Protection Clause, and federal Medicaid regulations.The United States District Court for the District of Columbia rejected the out-of-state hospitals' arguments and granted summary judgment in favor of the Centers for Medicare and Medicaid Services (CMS). The hospitals appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the QAF program does not discriminate against interstate commerce because it does not tax out-of-state hospitals, and the supplemental payments are based on in-state provision of medical care. The court also found that the program does not violate the Equal Protection Clause, as California could rationally decide to target subsidies to in-state hospitals serving a disproportionate share of Medi-Cal beneficiaries. Lastly, the court concluded that the QAF program does not violate federal Medicaid regulations, as the regulation in question pertains to base payments for specific services rendered to beneficiaries, not supplemental subsidies like the QAF payments. View "Asante v. Kennedy" on Justia Law