Justia Government & Administrative Law Opinion Summaries

A federal inmate serving a 210-month sentence challenged the method used by the Federal Bureau of Prisons (BOP) to calculate his good conduct time credits under 18 U.S.C. § 3624(b)(1), as amended by the First Step Act of 2018. The inmate argued that, following the amendments, he should receive a full 54 days of good conduct time credit for the last six months of his sentence, rather than a prorated amount. The BOP, however, interpreted the amended statute to require prorating the credit for any partial year, resulting in the inmate receiving 26 days of credit for the final six months instead of 54.The United States District Court for the District of New Jersey denied the inmate’s habeas petition. The court found that the plain language of the amended statute allowed for proration of good conduct time credits for partial years. As an alternative basis, the District Court also relied on Chevron deference to uphold the BOP’s interpretation. The court rejected the inmate’s additional claims under the Administrative Procedure Act (APA) and the Due Process Clause, finding them either precluded by statute or inapplicable to the rulemaking context.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory interpretation de novo. The Third Circuit affirmed the District Court’s judgment, holding that the First Step Act’s amendments, while deleting the word “prorated,” introduced language (“for each year”) that sets a rate of 54 days per year, thereby requiring proration for any partial year. The court concluded that the statute’s natural reading supports the BOP’s method of prorating credits for the last portion of a sentence. The Third Circuit also rejected the inmate’s constitutional and APA-based arguments, and found no basis for applying the rule of lenity. View "Thieme v. Warden Fort Dix FCI" on Justia Law

Gujarat Fluorochemicals Ltd., an Indian manufacturer, was subject to a countervailing duty investigation initiated by the U.S. Department of Commerce after Daikin America, Inc., a U.S. producer, filed petitions regarding imports of granular polytetrafluoroethylene (PTFE) resin from India and Russia. During the period of investigation, Gujarat purchased wind energy from Inox Wind Limited, a cross-owned Indian company that had received a subsidized land lease from the Indian government. Inox sold all its wind energy to Gujarat, which was used at Gujarat’s production facility to manufacture PTFE resin and other products. The wind energy from Inox represented a small fraction of the total energy consumed at the facility.Commerce determined that the subsidy received by Inox should be attributed to Gujarat under the cross-ownership regulation at 19 C.F.R. § 351.525(b)(6)(iv), resulting in a significant portion of the countervailing duty rate assessed against Gujarat. Commerce reasoned that because all of Inox’s wind energy was supplied to Gujarat, the input was “primarily dedicated” to Gujarat’s downstream production. Gujarat challenged this determination before the United States Court of International Trade, arguing that Commerce misapplied the “primarily dedicated” standard. The Trade Court agreed, finding that the regulation required more than mere consumption of the input by the downstream producer and that the facts did not support attributing the subsidy under the cross-ownership provision. The Trade Court ordered Commerce to remove the portion of the duty rate based on this attribution, and Commerce complied under protest.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Trade Court’s judgment. The Federal Circuit held that the cross-ownership regulation does not apply solely because the downstream producer is the sole consumer of the input. Instead, the regulation requires a fact-specific inquiry into whether the input’s production is primarily dedicated to the downstream product, as reflected in the regulatory history and examples. The court affirmed the removal of the subsidy attribution and the adjusted duty rate. View "GUJARAT FLUOROCHEMICALS LTD. v. US " on Justia Law

Petitioners, resident taxpayers and registered voters in Oklahoma County, challenged the constitutionality of Senate Bill 632, which sought to create business court divisions within the district courts of Oklahoma County and Tulsa County. The Act provided for the appointment of business court judges by the Governor, with confirmation by the Senate and candidate lists supplied by the Speaker of the House. It also set forth qualifications, terms, salaries, and operational details for these judges and courts. Petitioners argued that the Act violated their constitutional rights, particularly the right to elect district judges, and would result in the unlawful expenditure of public funds.Prior to review by the Supreme Court of the State of Oklahoma, the Honorable Lonnie Paxton and Kyle Hilbert, legislative leaders named as respondents, moved for dismissal based on legislative immunity, which the court granted. The Governor, the remaining respondent, moved to dismiss the case, arguing he was not a proper party. The court denied this motion, finding the Governor’s role in appointing business court judges central to the dispute. The Oklahoma Association for Justice filed an amicus brief supporting Petitioners. The court assumed original jurisdiction, issued a temporary stay of the Act’s effectiveness, and heard oral arguments.The Supreme Court of the State of Oklahoma held that Petitioners had standing as both taxpayers and voters. The court found Senate Bill 632 unconstitutional because it violated Article VII, Section 9 of the Oklahoma Constitution by circumventing the requirement that district judges be elected by voters. The court further determined that the unconstitutional provisions were not severable from the rest of the Act, rendering the entire Act void and unenforceable. The petition for declaratory relief was granted, and the temporary stay remained in effect pending any rehearing. View "White v. Stitt" on Justia Law

A proposed residential development in downtown Livermore, California, was the subject of a dispute between a community group and the city. The city had entered into agreements with a developer, Eden Housing, to build affordable workforce housing and, as part of a 2022 resolution, authorized the construction and improvement of a new public park, Veterans Park. Move Eden Housing, a local group, sought to challenge this resolution through a referendum, arguing that the city’s approval of the park was a legislative act subject to voter review.The Alameda County Superior Court initially denied Move Eden’s petition for a writ of mandate, finding the city’s resolution to be administrative and not subject to referendum. On appeal, the California Court of Appeal, First Appellate District, Division Five, reversed, holding that the park approval was a legislative act and ordered the city to process the referendum petition. In response, the city repealed the 2022 resolution and enacted a new 2024 resolution that reaffirmed the development agreement but omitted the Veterans Park provisions.Move Eden then argued that the city’s adoption of the 2024 resolution violated California Elections Code section 9241, which prohibits reenactment of a repealed ordinance for one year. The trial court agreed and granted Move Eden’s motion to compel compliance with the writ of mandate.On further appeal, the California Court of Appeal, First Appellate District, Division Five, reversed the trial court’s order. The appellate court held that section 9241 did not prohibit the city from adopting the 2024 resolution because it involved only administrative acts implementing prior legislative determinations not challengeable by referendum. The court clarified that the referendum power and section 9241’s restrictions apply only to legislative acts, not administrative actions. The matter was remanded with instructions to deny Move Eden’s motion. View "Move Eden Housing v. City of Livermore" on Justia Law

Novo Nordisk, a pharmaceutical manufacturer, challenged the implementation of the Drug Price Negotiation Program established by the Inflation Reduction Act of 2022. The Program requires the Department of Health and Human Services, through the Centers for Medicare and Medicaid Services (CMS), to negotiate prices for certain high-expenditure drugs covered by Medicare. In the first round of selections, CMS grouped six of Novo Nordisk’s insulin aspart products as a single “negotiation-eligible drug” and selected them for price negotiation. Novo Nordisk signed the required agreements to participate but subsequently filed suit, arguing that CMS’s grouping of its products and the procedures used to implement the Program violated statutory and constitutional provisions.The United States District Court for the District of New Jersey granted summary judgment in favor of the government. The court found it lacked subject matter jurisdiction to review CMS’s decision to treat the six products as one drug due to a statutory bar on judicial review. It also held that Novo Nordisk lacked standing to challenge the identification of more than ten drugs for the initial pricing period. The court rejected Novo Nordisk’s claims under the unconstitutional conditions doctrine, the Due Process Clause, the nondelegation doctrine, and the First Amendment, concluding that the Program did not deprive the company of a protected property interest, that Congress provided an intelligible principle to guide CMS, and that the Program primarily regulated conduct rather than speech.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that the statutory bar on judicial review precluded consideration of Novo Nordisk’s challenge to the grouping of its products. The court also held that CMS was authorized to implement the Program through guidance for the initial years without notice and comment rulemaking, that the Act did not violate the nondelegation doctrine or the Due Process Clause, and that Novo Nordisk’s First Amendment claim was foreclosed by precedent. View "Novo Nordisk Inc. v. Secretary US Dept & Health and Human Services" on Justia Law

Christopher Toland was sentenced in 1993 to a lengthy prison term for rape, kidnapping, and related offenses, making him eligible for parole in 2004. Between 2004 and 2020, the Pennsylvania Parole Board denied him parole fourteen times, often contrary to recommendations from the Department of Corrections. Toland filed a petition for review in the Commonwealth Court of Pennsylvania, seeking mandamus relief and alleging constitutional violations in the Board’s parole denials from 2017, 2018, and 2019. He claimed the Board relied on false information, acted arbitrarily, and applied parole standards retroactively in violation of ex post facto prohibitions.The Commonwealth Court overruled the Parole Board’s preliminary objections to Toland’s claims, allowing discovery to proceed. When Toland requested documents related to his parole eligibility, the Parole Board objected, citing its own regulation (37 Pa. Code § 61.2) that designates its records as “private, confidential and privileged.” The Commonwealth Court rejected the Board’s objections, finding that Toland, as the beneficiary of the privilege, could waive it. The Board then filed an interlocutory appeal.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court’s order, but on a different basis. The Supreme Court held that the Parole Board does not have the authority to create an evidentiary privilege through its own regulation. Therefore, Section 61.2 does not establish a privilege that can be invoked to prevent disclosure of documents in discovery. The Court clarified that only privileges created by the legislature, the constitution, or the common law are recognized in Pennsylvania courts, and no such privilege exists under Section 61.2. The Supreme Court’s disposition was to affirm the lower court’s order. View "Toland v. PBPP" on Justia Law

The case concerns challenges to Executive Order No. 14160, issued in January 2025, which seeks to deny birthright citizenship to children born in the United States after its effective date if their fathers are not U.S. citizens or lawful permanent residents and their mothers are either unlawfully or temporarily present in the country. Plaintiffs include individual immigrants, nonprofit organizations, and a coalition of states and local governments. They allege that the Executive Order violates the Citizenship Clause of the Fourteenth Amendment, 8 U.S.C. § 1401(a), the equal protection component of the Fifth Amendment, the Separation of Powers doctrine, and the Administrative Procedure Act. The plaintiffs seek declaratory and injunctive relief to prevent enforcement of the Order.The United States District Court for the District of Massachusetts granted preliminary injunctions to both sets of plaintiffs, finding they were “exceedingly likely” to succeed on their claims under the Citizenship Clause and § 1401(a). The injunctions barred federal agencies and officials from enforcing the Executive Order against the plaintiffs and, in the case brought by the states, issued a nationwide injunction to provide complete relief. The government appealed, challenging the plaintiffs’ standing, the scope of the injunctions, and the merits of the constitutional and statutory claims.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s findings that the plaintiffs have Article III standing and are likely to succeed on the merits. The First Circuit held that the Executive Order’s denial of birthright citizenship to children born in the United States under the specified circumstances violates both the Citizenship Clause of the Fourteenth Amendment and 8 U.S.C. § 1401(a), as interpreted by United States v. Wong Kim Ark and subsequent precedent. The court affirmed the preliminary injunctions in part, vacated them in part as to agency defendants, and remanded for further proceedings consistent with its opinion. View "Doe v. Trump" on Justia Law

A group of out-of-state pig farmers and a pork processor challenged a Massachusetts law that prohibits the use of certain confinement methods for breeding pigs (specifically, gestation crates) and bans the sale in Massachusetts of pork products derived from pigs confined in such a manner. The plaintiffs, who operate outside Massachusetts and use these confinement methods, argued that the law discriminates against out-of-state producers and is preempted by federal statutes. The law was enacted by ballot initiative and became enforceable after the Supreme Court’s decision in National Pork Producers Council v. Ross.The United States District Court for the District of Massachusetts dismissed most of the plaintiffs’ claims, including those based on the Privileges and Immunities Clause, preemption by the Federal Meat Inspection Act (FMIA) and the Packers and Stockyards Act (PSA), the Full Faith and Credit Clause, the Due Process Clause, and the Import-Export Clause. The court allowed the dormant Commerce Clause claim to proceed, but ultimately granted summary judgment against the plaintiffs on that claim as well, after severing a provision of the law that it found discriminatory (the “slaughterhouse exemption”). The court found that the remaining provisions of the law did not discriminate against out-of-state interests and did not impose a substantial burden on interstate commerce.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that the Massachusetts law does not discriminate against out-of-state producers in purpose or effect, does not impose a substantial burden on interstate commerce under the Pike balancing test, and is not preempted by the FMIA or PSA. The court also rejected the plaintiffs’ claims under the Privileges and Immunities Clause, Full Faith and Credit Clause, Due Process Clause, and Import-Export Clause. The court found no procedural error in the district court’s handling of the case. View "Triumph Foods, LLC v. Campbell" on Justia Law

The case concerns a challenge to the validity of Measure C, a citizens’ initiative placed on the ballot by the City of San Diego for the March 2020 election. Measure C proposed an increase in the city’s transient occupancy tax, with revenues earmarked for homelessness programs, street repairs, and convention center improvements. The measure also authorized the City to issue bonds repaid from the new tax revenues. Measure C received 65.24 percent of the vote, and the city council subsequently passed resolutions declaring the measure approved and authorizing the issuance of related bonds.After the election, Alliance San Diego and other plaintiffs filed actions challenging the City’s resolution declaring Measure C had passed, arguing it was invalid. The City responded with a validation complaint seeking judicial confirmation of the validity of Measure C and the related bond resolutions. California Taxpayers Action Network (CTAN) and other opponents answered, contending that Measure C required a two-thirds vote and was not a bona fide citizens’ initiative. The Superior Court of San Diego County initially granted a motion for judgment on the pleadings, finding that a two-thirds vote was required, and entered judgment against the City. On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reversed and remanded for further proceedings to determine whether Measure C was a bona fide citizens’ initiative.On remand, the trial court conducted a bench trial and rejected CTAN’s arguments, finding that it had subject matter jurisdiction, the case was ripe, the special fund doctrine exempted the bonds from the two-thirds vote requirement, and Measure C was a bona fide citizens’ initiative requiring only a simple majority vote. The California Court of Appeal affirmed the trial court’s judgment, holding that Measure C and the related bond resolutions were valid, and that the trial court properly excluded certain hearsay evidence. View "Alliance San Diego v. California Taxpayers Action Network" on Justia Law

Two advocacy organizations submitted a petition to the United States Patent and Trademark Office (PTO) seeking a rule that would limit the PTO’s discretion to institute inter partes review (IPR) and post-grant review (PGR) proceedings under the America Invents Act. Their proposed rule would have prevented institution of such proceedings in certain circumstances when the patent owner objected and met specific criteria, such as being the original applicant and having small entity status. The PTO denied the petition, stating that the issues overlapped with topics already under consideration in a separate request for public comment and that the suggestions would be considered in any future rulemaking.After the denial, the organizations filed a lawsuit in the United States District Court for the District of Columbia, alleging that the PTO’s denial violated the Administrative Procedure Act and the America Invents Act. They argued that the PTO failed to act within a reasonable time, did not provide adequate reasons for denial, and was required to engage in notice-and-comment rulemaking. The PTO moved to dismiss the complaint for lack of standing. The district court granted the motion, finding that the organizations lacked both organizational and associational standing because they failed to show that any member faced a concrete, non-speculative injury as a result of the PTO’s denial.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the dismissal de novo. The court held that the organizations lacked associational standing because they did not demonstrate that any member suffered an actual or imminent injury traceable to the PTO’s denial of the petition. The court found the alleged injury too speculative, relying on a chain of uncertain future events involving third-party actions. The Federal Circuit affirmed the district court’s dismissal for lack of standing. View "US INVENTOR, INC. v. PTO " on Justia Law