Justia Government & Administrative Law Opinion Summaries

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Fabian Grey, a Jamaican citizen and lawful permanent resident in the U.S., applied for naturalization in 2016. After delays in processing his application, Grey filed a lawsuit seeking a court order to declare him eligible for naturalization and to compel the United States Citizenship and Immigration Services (USCIS) to naturalize him. He also sought documents from USCIS under the Freedom of Information Act (FOIA) and amended his lawsuit to compel USCIS to produce those documents. The district court granted summary judgment to USCIS on both claims, allowing the agency to withhold or redact certain documents under FOIA’s law enforcement exemption and concluding that Grey was ineligible for naturalization due to lying under oath during his deposition.The United States District Court for the District of South Carolina found that Grey had lied under oath about a 2016 criminal charge for misprision of a felony during his deposition. The court also determined that USCIS had appropriately responded to Grey’s FOIA request, producing substantial documentation and justifiably withholding or redacting certain documents. Grey appealed the district court’s rulings on both the FOIA and naturalization claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The appellate court agreed that USCIS was entitled to withhold certain information under FOIA’s law enforcement exemption and that Grey’s false testimony during his deposition disqualified him from demonstrating the good moral character required for naturalization. The court concluded that Grey was ineligible for citizenship and upheld the district court’s summary judgment in favor of USCIS. View "Grey v. Alfonso-Royals" on Justia Law

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Derrick Clark and Shawn Mesner worked for Didion Milling, Inc., a corn milling company. In May 2017, Didion’s grain mill exploded, killing five employees. The Occupational Health and Safety Administration (OSHA) investigated and referred Didion for criminal prosecution. The government charged Didion and several employees with federal crimes related to their work at the mill. Clark and Mesner proceeded to trial, challenging the district court’s evidentiary rulings, jury instructions, the indictment, the sufficiency of the evidence, and the constitutionality of their convictions.The United States District Court for the Western District of Wisconsin convicted Clark on four counts and Mesner on two counts. Clark was found guilty of conspiracy to commit federal offenses, false entries in records, using false documents within the EPA’s jurisdiction, and obstruction of agency proceedings. Mesner was found guilty of conspiracy to commit mail and wire fraud and conspiracy to commit federal offenses. Both defendants were sentenced to 24 months’ imprisonment and one year of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court vacated Mesner’s conviction on Count 4, remanding for an entry of judgment of acquittal and further proceedings consistent with the opinion. The court affirmed the district court’s evidentiary rulings and jury instructions, as well as Clark’s convictions and Mesner’s conviction on Count 1. The court found sufficient evidence to support the convictions and determined that the jury instructions, when considered as a whole, accurately reflected the law. The court also rejected challenges to the constitutionality of the OSHA regulation involved. View "USA v Mesner" on Justia Law

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David J. Rudometkin was found guilty of several offenses by a military judge in 2018 and sentenced to seventeen years of confinement. His post-trial motion for a mistrial was denied by another military judge after the original judge was suspended for inappropriate conduct. Rudometkin then submitted FOIA requests to the Army and the Department of Defense for records related to the judges involved. The government either did not respond meaningfully or rejected the requests under FOIA exemptions.Rudometkin filed a pro se complaint in the District Court in 2020, challenging the government's withholding of records. He later amended his complaint to focus solely on records related to the appointment of the Chief Trial Judge. The District Court granted the government's motion for summary judgment, concluding that the government had adequately searched for records and appropriately withheld information under Exemption 5’s deliberative-process privilege. The court also denied Rudometkin’s motions to amend his complaint to include his original FOIA claim regarding the Army’s investigatory records of the first judge.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the government did not establish that it properly withheld records under Exemption 5’s deliberative-process privilege and had not shown that it released all reasonably segregable information. The court reversed and remanded on the segregability issue. However, the court affirmed the District Court’s denial of Rudometkin’s motion to amend his complaint, as his FOIA claim regarding the Army’s investigatory records of the first judge was now live in a separate action. View "Rudometkin v. USA" on Justia Law

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Fifteen restaurants and bars in Ohio and Florida challenged the Small Business Administration's (SBA) operation of the COVID-19 relief program under the American Rescue Plan Act of 2021 (ARPA). The plaintiffs argued that the SBA did not process their applications for the Restaurant Revitalization Fund (RRF) in the order received, as required by law, and that the SBA failed to recover improperly awarded funds. They sought an injunction to prevent the SBA from closing the RRF until all applications were adjudicated and improperly awarded funds were returned and redistributed.The United States District Court for the Northern District of Ohio dismissed the case for lack of subject-matter jurisdiction and failure to state a claim. The court held that the plaintiffs lacked standing to request enforcement actions to recover RRF grants and that the case was moot because the covered period for using the funds had ended, and Congress had rescinded unobligated funds.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the case was moot because the RRF program expired on March 11, 2023, and any awarded funds could no longer be used by the plaintiffs. The court concluded that even if the plaintiffs were awarded grants, they would be required to return the funds to the Treasury, rendering any court decision ineffectual. The court did not address the SBA's additional arguments regarding standing or mootness, as the expiration of the covered period was sufficient to moot the case. View "W6 Restaurant Group, Ltd v. Loeffler" on Justia Law

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A man named Yoon Suk Chang was injured at the American Memorial Park on Saipan when his foot got caught in a large hole in a grassy area. He suffered severe ankle injuries, which required surgery and led to significant medical expenses and financial losses. Chang filed a negligence claim under the Federal Tort Claims Act (FTCA) against the United States, alleging that the National Park Service (NPS) allowed a dangerous hole to go unrepaired.The District Court for the Northern Mariana Islands dismissed Chang's complaint, citing the discretionary function exception of the FTCA. The court reasoned that the decisions on how to inspect and maintain the grassy areas involved policy considerations, such as safety, public access, and aesthetics. Therefore, the court concluded that the discretionary function exception applied, and the United States was immune from the lawsuit.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's judgment. The Ninth Circuit held that the discretionary function exception did not apply because the routine maintenance of a grassy lawn did not involve government employees balancing public policy considerations. The court emphasized that the NPS's failure to repair a hole in a regularly maintained grass area was a matter of routine maintenance, which is not protected by the discretionary function exception. The case was remanded for further proceedings consistent with this opinion. View "Chang v. United States" on Justia Law

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Albert Lobo, a Deputy Sheriff in San Bernardino County, California, contracted pneumonia in early 2010, which progressed to sepsis and resulted in multiple amputations, leaving him permanently and totally disabled. He received disability retirement and workers' compensation benefits at the county and state levels between 2012 and 2014. In March 2015, Lobo filed a claim for disability-based benefits under the Public Safety Officers’ Benefits Act of 1976 (PSOB Act) with the Public Safety Officers’ Benefits Office (PSOB Office) of the Bureau of Justice Assistance (Bureau) of the U.S. Department of Justice.The PSOB Office denied Lobo's claim in May 2016, a decision upheld by a hearing officer in October 2017 and the Bureau’s Director in August 2023. The denials were based on the finding that Lobo had not proven he contracted pneumonia in the line of duty. The Bureau's Director emphasized the lack of evidence showing that Lobo caught pneumonia at the jails where he worked, despite acknowledging that Lobo was permanently and totally disabled due to pneumonia.The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the Bureau had not made sufficient efforts to obtain potentially crucial information about whether there were pneumonia-infected individuals at the jails where Lobo worked. The court noted that such information could be highly material to determining the origin of Lobo's pneumonia. Consequently, the court vacated the Director’s decision and remanded the case for further proceedings, instructing the Bureau to make reasonable efforts to obtain the necessary information from the jails and to reassess the claim in light of any new evidence obtained. View "Lobo v. Department of Justice" on Justia Law

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In this case, Sacramento Television Stations Inc. (Sac TV) sought additional audio and video recordings from the City of Roseville (City) under the California Public Records Act (CPRA). The recordings pertained to an incident on April 6, 2023, where Roseville Police Department (Roseville PD) officers discharged firearms at a suspect, Eric J. Abril, resulting in injuries and a fatality. The City provided limited footage, arguing that further disclosure would interfere with an active investigation.The Superior Court of Placer County ruled that the City had shown by clear and convincing evidence that releasing more footage would substantially interfere with the ongoing investigation into Abril's criminal case. Consequently, the court denied Sac TV's petition for additional recordings. Sac TV then filed a petition for writ of mandate in the California Court of Appeal, Third Appellate District, seeking to overturn the superior court's decision.The California Court of Appeal reviewed the case and concluded that the superior court's finding of an "active investigation" was not supported by substantial evidence. The appellate court determined that the City had not provided sufficient detail to demonstrate how further disclosure would interfere with an active investigation. The court also found that the superior court correctly interpreted that more disclosure was required under subdivision (e) of section 7923.625 of the Government Code, but it had not determined the extent of additional disclosure needed.The Court of Appeal vacated the superior court's ruling and directed it to hold further proceedings, including an in camera review of the City's recordings, to determine the extent of additional disclosure required. The appellate court emphasized the importance of providing sufficient context to understand the events captured in the recordings, as mandated by the CPRA. View "Sacramento Television Stations Inc. v. Superior Court" on Justia Law

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The plaintiffs, a group of consumers, filed a lawsuit against General Motors (GM) and Robert Bosch LLC, alleging that the companies misled consumers about the emissions produced by certain Chevrolet Cruze vehicles. They claimed that the vehicles emitted higher levels of nitrogen oxides (NOx) than advertised and that the emissions control systems were manipulated to pass regulatory tests. The plaintiffs sought damages under various state fraud laws and the Racketeer Influenced and Corrupt Organizations (RICO) Act.The United States District Court for the Eastern District of Michigan initially dismissed some of the plaintiffs' claims, ruling that those based on the Environmental Protection Agency (EPA) standards were preempted by the Clean Air Act. The court allowed other claims to proceed, particularly those alleging that GM's advertising misled consumers about the vehicles' emissions. However, after the Sixth Circuit's decision in a similar case (In re Ford Motor Company F-150 and Ranger Truck Fuel Economy Marketing and Sales Practices Litigation), the district court revisited its decision and dismissed the remaining fraud claims, concluding they were preempted by federal law. The court also granted summary judgment to the defendants on the RICO claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court should determine whether the plaintiffs' remaining claims could proceed without relying on a disagreement with the EPA's determinations. The court remanded the case for the district court to decide if the claims were preempted under the analysis described. The court affirmed the dismissal of the RICO claims and the denial of the plaintiffs' post-judgment motion to vacate the judgment in part and approve a preliminary settlement agreement. The case was remanded for further proceedings consistent with the opinion. View "Counts v. General Motors, LLC" on Justia Law

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A reporter for The Providence Journal submitted an Access to Public Records Act (APRA) request to the Office of Governor Daniel J. McKee, seeking a list of individuals who received preferred license plates. The Governor’s Office denied the request, citing the federal Driver’s Privacy Protection Act (DPPA) and state law, which protect such information from disclosure. The Providence Journal argued that the DPPA did not apply because the records were maintained by the Governor’s Office, not the Department of Motor Vehicles (DMV).The Rhode Island Office of the Attorney General upheld the Governor’s Office’s denial, stating that the Governor’s Office effectively acts as an agent of the DMV in this context. LMG Rhode Island Holdings, Inc., the publisher of The Providence Journal, then filed a complaint for declaratory and injunctive relief in the Superior Court, arguing that the denial violated APRA. The Superior Court dismissed the complaint, agreeing with the Attorney General that the DPPA applied to the Governor’s Office in this context and that the requested information was exempt from disclosure under APRA.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court’s judgment. The Court held that the DPPA applies to the Governor’s Office when it processes preferred plate applications, as it acts as an agent of the DMV. The Court also concluded that the information requested was protected by the DPPA, as it pertains to motor vehicle registration records. Consequently, the denial of the APRA request was lawful.Additionally, the Supreme Court affirmed the Superior Court’s denial of the Governor’s Office’s motion for attorneys’ fees. The Court found that the plaintiff’s case had some grounding in existing law and was not frivolous, thus not warranting an award of attorneys’ fees. View "LMG Rhode Island Holdings, Inc. v. Office of Governor McKee" on Justia Law

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Abigail Stratton filed a petition with the Office of Special Masters under the National Childhood Vaccine Injury Act, alleging that the Gardasil® vaccine caused her to develop postural orthostatic tachycardia syndrome (POTS) and autonomic dysfunction. These conditions are not listed in the Vaccine Injury Table, requiring her to prove actual causation by a preponderance of the evidence. After filing a Notice of Intent to Withdraw to pursue her claim in federal district court, the Chief Special Master concluded the proceedings on the merits and later awarded her partial attorneys’ fees and costs.The Secretary of Health and Human Services opposed the fee application, arguing that Stratton did not file her petition with the good faith intent of litigating the claim and that there was no reasonable basis for her claim. The Chief Special Master found that Stratton had satisfied both the good faith and reasonable basis requirements and awarded partial fees. The Court of Federal Claims affirmed the Chief Special Master’s decision, concluding that the finding of a reasonable basis was not arbitrary and capricious, and awarded $8,876.86 for attorneys’ fees and costs. The Secretary appealed this decision.The United States Court of Appeals for the Federal Circuit reviewed the case and found that the Chief Special Master failed to adequately explain the determination that Stratton’s petition had a reasonable basis. The court noted that the Chief Special Master acknowledged the Secretary’s concerns about the sufficiency of the medical records but dismissed them without sufficient explanation. The Federal Circuit vacated the decision and remanded the case for further proceedings consistent with its opinion, requiring a more detailed explanation of why the evidence provided a reasonable basis for Stratton’s claim. View "Stratton v. Health and Human Services" on Justia Law