Justia Government & Administrative Law Opinion Summaries

A mother and daughter drowned while floating on innertubes on the Turkey River after going over a low-head dam. Their estates sued the State of Iowa, Fayette County, the Fayette County Conservation Board, and the City of Clermont, alleging negligence and premises liability for failing to maintain warnings about the dam. The defendants moved to dismiss the claims.The Iowa District Court for Fayette County dismissed all claims. The court concluded that the claims were barred by the public-duty doctrine and that the petition failed to meet the heightened pleading requirements in Iowa Code § 670.4A. The court also dismissed the claims against the State, referring generally to the reasons set forth in the State’s motion, which included qualified immunity, sovereign immunity, discretionary function immunity, and the public-duty doctrine.The Iowa Supreme Court reviewed the case and reversed the district court’s dismissal. The court held that the heightened pleading requirements did not apply to the estates’ common law tort claims of negligence and premises liability. The court also determined that the public-duty doctrine did not bar the claims, as the allegations involved affirmative acts of negligence by the defendants. Additionally, the court found that the State’s sovereign immunity and discretionary function immunity did not apply at this stage, as the petition alleged inattention rather than considered choices by the State. The court also rejected the recreational immunity defense, concluding that the estates sufficiently pleaded an exception to the statute.The Iowa Supreme Court reversed the district court’s dismissal of the claims and remanded the case for further proceedings. View "Estate of Kahn v. City of Clermont, Iowa" on Justia Law

Promenade D’Iberville, LLC, the owner and developer of a large retail shopping center in D’Iberville, Mississippi, discovered soil issues during construction in 2009. The problems were linked to the use of OPF42, a soil stabilizer containing bed ash from Jacksonville Electric Authority (JEA), a Florida public utility. Promenade filed a lawsuit in 2010 in the Harrison County Circuit Court against several parties, including JEA, alleging damages from the defective product.The Harrison County Circuit Court granted JEA’s motion to dismiss for lack of subject-matter jurisdiction, citing sovereign immunity based on California Franchise Tax Board v. Hyatt (Hyatt III). The court also held that the Full Faith and Credit Clause and comity principles required dismissal due to Florida’s presuit notice and venue requirements. Promenade appealed the decision.The Supreme Court of Mississippi reviewed the case and found that Hyatt III does not apply to JEA, as it is not an arm of the State of Florida but an instrumentality of the City of Jacksonville. The court also determined that neither the Full Faith and Credit Clause nor comity principles mandated dismissal. The court held that Promenade should be allowed to proceed with its claims against JEA in Mississippi, seeking damages similar to those allowed under Mississippi’s constitution for property damage.The Supreme Court of Mississippi reversed the trial court’s judgment of dismissal and remanded the case for further proceedings consistent with its opinion. View "The Promenade D'Iberville, LLC v. Jacksonville Electric Authority" on Justia Law

Two air ambulance providers, Guardian Flight, LLC, and Med-Trans Corporation, sued Health Care Service Corporation (HCSC) for failing to timely pay dispute resolution awards under the No Surprises Act (NSA). The providers also claimed that HCSC improperly denied benefits under the Employee Retirement Income Security Act (ERISA) and was unjustly enriched under Texas law.The United States District Court for the Northern District of Texas dismissed the providers' complaint. The court found that the NSA does not provide a private right of action for enforcing dispute resolution awards. It also dismissed the ERISA claim for lack of standing, as the providers did not show that the beneficiaries suffered any injury since the NSA shields them from liability. Lastly, the court dismissed the quantum meruit claim, stating that the providers did not perform their services for HCSC's benefit. The court also denied the providers' request for leave to amend their complaint, deeming it futile.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The appellate court agreed that the NSA does not contain a private right of action and that the statute's text and structure support this conclusion. The court also upheld the dismissal of the ERISA claim, reiterating that the beneficiaries did not suffer any concrete injury. Finally, the court affirmed the dismissal of the quantum meruit claim, as the providers did not render services for HCSC's benefit. The appellate court also found no abuse of discretion in the district court's denial of leave to amend the complaint. View "Guardian Flight v. Health Care Service" on Justia Law

Steve Eggleston sued Clark County and Georgina Stuart, a social worker, alleging violations of his due process rights under 42 U.S.C. § 1983 and intentional infliction of emotional distress (IIED). Eggleston claimed that Stuart coerced him into signing temporary guardianship papers for his children during an ongoing child abuse/neglect investigation by threatening that his children would be permanently removed from his care if he did not comply. Stuart and Clark County moved for summary judgment, arguing that their actions were protected by qualified immunity and discretionary-act immunity. The district court denied their motion.The Eighth Judicial District Court of Nevada denied the motion for summary judgment, leading Stuart and Clark County to file a petition for a writ of mandamus challenging the order. The district court found that there were genuine issues of material fact regarding whether Stuart's conduct violated clearly established law and whether her actions were protected by discretionary-act immunity.The Supreme Court of Nevada reviewed the case and granted the petition for a writ of mandamus. The court held that Stuart was entitled to qualified immunity on Eggleston's substantive and procedural due process claims because her conduct did not violate any clearly established constitutional rights. The court also held that Stuart was entitled to discretionary-act immunity on Eggleston's IIED claim, as her actions involved individual judgment and were based on considerations of social policy. The court directed the district court to vacate the order denying summary judgment and to enter an order granting summary judgment in favor of Stuart and Clark County. View "Clark County v. District Court" on Justia Law

West Virginia filed a complaint in state court against CaremarkPCS Health, LLC, a pharmacy benefit manager (PBM), alleging that Caremark unlawfully drove up the cost of insulin, causing financial harm to the state. The complaint included state law claims of civil conspiracy, unjust enrichment, fraud, and breach of contract. Caremark removed the case to federal court under the federal officer removal statute, 28 U.S.C. § 1442(a)(1), arguing that its conduct in negotiating rebates, which is central to the complaint, was performed under the direction of the federal government as part of its work for federal health plans.The United States District Court for the Northern District of West Virginia found that removal was unwarranted and remanded the case to state court. The district court concluded that Caremark failed to meet the requirements for federal officer removal and noted that West Virginia had disclaimed any federal claims in its complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The Fourth Circuit held that Caremark was entitled to remove the case to federal court under § 1442(a)(1). The court found that Caremark acted under a federal officer because it administered health benefits for federal employees under contracts with FEHBA carriers, which are supervised by the Office of Personnel Management (OPM). The court also determined that Caremark had a colorable federal defense, specifically that federal law preempted West Virginia's claims. Finally, the court concluded that the charged conduct was related to Caremark's federal work, as the rebate negotiations for federal and non-federal clients were indivisible. Thus, the Fourth Circuit reversed the district court's remand decision and returned the case to the district court for further proceedings. View "West Virginia ex rel. Hunt v. CaremarkPCS Health, L.L.C." on Justia Law

In October 2017, the FBI mistakenly raided the home of Hilliard Toi Cliatt, Curtrina Martin, and her 7-year-old son in suburban Atlanta, instead of the intended gang hideout. The error occurred due to Special Agent Guerra's reliance on a personal GPS device and the team's failure to notice the correct street sign and house number. The raid resulted in personal injuries and property damage. The plaintiffs sued the United States under the Federal Tort Claims Act (FTCA) for the officers' negligent and intentional actions.The district court granted summary judgment to the government, and the Eleventh Circuit affirmed. The Eleventh Circuit applied a unique approach to FTCA claims, holding that the law enforcement proviso in §2680(h) overrides all exceptions, including the discretionary-function exception, allowing intentional-tort claims to proceed without further analysis. The court also allowed the government to assert a Supremacy Clause defense, which it found valid, leading to summary judgment for the United States.The Supreme Court of the United States reviewed the case and held that the law enforcement proviso in §2680(h) overrides only the intentional-tort exception, not the discretionary-function exception or other exceptions in §2680. The Court also held that the Supremacy Clause does not afford the United States a defense in FTCA suits. The case was vacated and remanded to the Eleventh Circuit to reconsider whether the discretionary-function exception bars the plaintiffs' claims and to assess liability under Georgia state law without reference to a Supremacy Clause defense. View "Martin v. United States" on Justia Law

Simon Soto, a Marine Corps veteran, served from 2000 to 2006 and was medically retired due to post-traumatic stress disorder (PTSD). In 2016, Soto applied for combat-related special compensation (CRSC) and was approved, but his retroactive compensation was limited to six years due to the Barring Act's limitations period. Soto filed a class-action lawsuit arguing that the CRSC statute should displace the Barring Act's limitations period.The United States District Court for the Southern District of Texas granted summary judgment in favor of Soto and the class, holding that the CRSC statute provides its own settlement mechanism, thus displacing the Barring Act. However, the United States Court of Appeals for the Federal Circuit reversed this decision, stating that the CRSC statute does not explicitly grant settlement authority and therefore cannot displace the Barring Act.The Supreme Court of the United States reviewed the case and held that the CRSC statute does confer authority to settle CRSC claims, thereby displacing the Barring Act’s settlement procedures and limitations period. The Court reasoned that the CRSC statute authorizes the Secretary concerned to determine both the validity of CRSC claims and the amount due, creating a comprehensive compensation scheme. Consequently, the Supreme Court reversed the Federal Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Soto v. United States" on Justia Law

SWT Global Supply, Inc. (SWT Global), a Missouri-based manufacturer of electronic nicotine delivery system (ENDS) vaping products, sought review of the U.S. Food and Drug Administration's (FDA) denial of market authorization for its menthol-flavored ENDS products. The FDA denied the premarket tobacco product applications (PMTAs) submitted by SWT Global, citing insufficient evidence that the products would benefit adult users enough to outweigh the risks to youth.The FDA's decision was based on the Family Smoking Prevention and Tobacco Control Act of 2009, which requires new tobacco products to receive FDA authorization before being sold. The FDA determined that SWT Global's PMTAs lacked product-specific evidence demonstrating that the menthol-flavored ENDS products would attract adults away from combustible cigarettes and reduce overall harm. The FDA also found SWT Global's marketing plan insufficient to prevent youth access to the products.The United States Court of Appeals for the Eighth Circuit reviewed the case. SWT Global argued that the FDA's denial was arbitrary and capricious, claiming the FDA changed its position on the required scientific evidence and failed to justify its finding that the marketing plan was insufficient. The court referenced the Supreme Court's decision in Food & Drug Administration v. Wages & White Lion Investments, L.L.C., which held that the FDA's denial of PMTAs for flavored ENDS products was consistent with its guidance and did not violate the change-in-position doctrine.The Eighth Circuit found that the FDA did not change its position regarding the scientific evidence required for PMTAs and provided a satisfactory explanation for its decision. The court also determined that the FDA's treatment of menthol-flavored ENDS products was reasonable and consistent with its approach to other non-tobacco-flavored ENDS products. Consequently, the court denied SWT Global's petition for review. View "SWT Global Supply, Inc. v. U.S. Food & Drug Administration" on Justia Law

Krista Dozier slipped and fell on an unmarked puddle of water in the Jefferson County courthouse. She filed a tort action against Jefferson County, which moved to dismiss the case, claiming immunity under the Colorado Governmental Immunity Act (CGIA). Dozier argued that the spill was a "dangerous condition" of a public building, an exception to CGIA immunity. The district court found the County's response to the spill reasonable and dismissed Dozier's claims for lack of subject matter jurisdiction. The Colorado Court of Appeals reversed, holding that the reasonableness of the County's response was irrelevant to jurisdiction and that the County had waived CGIA immunity under the dangerous-condition exception.The Supreme Court of Colorado reviewed the case and reversed the judgment of the court of appeals. The court held that when disputed jurisdictional facts are inextricably intertwined with the merits, a plaintiff must demonstrate a likelihood of the existence of the facts necessary to establish a waiver of CGIA immunity. Additionally, the plaintiff must show that a public entity's negligent act or omission proximately caused the condition in question for the dangerous-condition exception to apply. The district court had found the County's response to the spill reasonable, concluding that Dozier failed to establish the spill as a "dangerous condition" and thus lacked jurisdiction over her claims.The Supreme Court of Colorado reinstated the district court's order dismissing Dozier's complaint, emphasizing that the plaintiff must demonstrate a likelihood that the public entity's negligent act or omission proximately caused the dangerous condition to establish a waiver of CGIA immunity. View "Jefferson Cnty. v. Dozier" on Justia Law

Citizens for a Better Eureka (CBE) filed a petition challenging the City of Eureka's decision to redevelop a city-owned parking lot into affordable housing, claiming the project was improperly exempted from the California Environmental Quality Act (CEQA). The City Council had adopted a resolution authorizing the reduction or removal of public parking to facilitate the development, citing a Class 12 CEQA exemption for surplus government property sales. CBE argued that the project was unlawfully piecemealed and that the entire redevelopment should be considered under CEQA.The Humboldt County Superior Court dismissed the petition, agreeing with the Wiyot Tribe's motion that the Tribe, selected as the developer for the project, was a necessary and indispensable party to the proceedings. The court found that the Tribe could not be joined due to its sovereign immunity, and thus, the case could not proceed without it.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court affirmed the lower court's decision, holding that the Tribe was indeed a necessary and indispensable party. The court reasoned that the Tribe had significant interests in the project, having invested time and resources into its development. The court also found that any judgment in favor of CBE would prejudice the Tribe by hindering its ability to proceed with the project. Additionally, the court noted that CBE failed to join the Tribe within the statutory period, further justifying the dismissal. The court concluded that the trial court did not abuse its discretion in dismissing the petition. View "Citizens for a Better Eureka v. City of Eureka" on Justia Law