Justia Government & Administrative Law Opinion Summaries

A fatal traffic accident occurred when a tractor trailer, driven by Andre Hill, ran a stop sign and collided with a vehicle driven by Olivia Mendoza, resulting in her death. Prior to the accident, Hill had picked up produce from Irigoyen Farms for delivery to a Walmart distribution center. The transportation of the produce involved several intermediaries: Irigoyen Farms contracted with a freight broker, who in turn contracted with other logistics companies, ultimately resulting in Hill being hired as an independent contractor by the motor carrier. Law enforcement determined that Hill’s extreme fatigue contributed to the crash.The decedent’s mother, Christina Casarez, filed suit in the Superior Court of Fresno County against Irigoyen Farms and Walmart, alleging motor vehicle negligence, general negligence, and wrongful death. She claimed that both defendants were directly negligent in their roles: Walmart for imposing contractual requirements that allegedly incentivized unsafe conduct, and Irigoyen Farms for loading the truck and sending Hill on his way despite knowledge of his fatigue. Both defendants moved for summary judgment, arguing that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) preempted Casarez’s claims. The superior court agreed, granting summary judgment in favor of both defendants.On appeal, the California Court of Appeal, Fifth Appellate District, reviewed the superior court’s decision de novo. The appellate court held that the FAAAA expressly preempts state law negligence claims against parties whose actions relate to the price, route, or service of a motor carrier with respect to the transportation of property, regardless of whether the party is a motor carrier, broker, or shipper. The court further held that the FAAAA’s safety exception did not apply because the claims did not directly concern the safety of the motor vehicle itself. The appellate court affirmed the superior court’s judgments in favor of Irigoyen Farms and Walmart. View "Casarez v. Irigoyen Farms" on Justia Law

Plaintiffs alleged that the City of Berkeley violated the Ralph M. Brown Act during three city council meetings in late 2023 and early 2024. At each meeting, disruptions from attendees made it impossible for the council to conduct business. The mayor determined that order could not be restored by removing disruptive individuals but did not order the meeting room cleared. Instead, the meetings were recessed and reconvened in a different, smaller room, which could not accommodate all nondisruptive members of the public. The press was allowed to attend in person, and the public could participate by video, but the council did not return to the original meeting room or attempt to remove only the disruptive individuals.The Alameda County Superior Court sustained the defendants’ demurrer without leave to amend, finding that section 54957.9 of the Brown Act did not require the city council to first attempt to remove disruptive individuals before determining that order could not be restored. The court also concluded that the city council complied with the statute by recessing and reconvening the meetings in a different room with the press present. The action was dismissed with prejudice, and plaintiffs appealed.The California Court of Appeal, First Appellate District, Division Four, reviewed the case de novo. The court held that section 54957.9 requires a legislative body to order the meeting room cleared and continue in session in the same room, not to recess and reconvene in a different location. The statute does not authorize relocating the meeting as a response to disruption. Because plaintiffs’ complaint alleged that the city council did not clear the meeting room but instead moved the meeting, the court found that a claim for relief was properly stated. The judgment was reversed. View "Berkeley People's Alliance v. City of Berkeley" on Justia Law

Colorado established a Universal Preschool Program (UPK) following a 2020 voter-approved proposition and subsequent legislation. The program provides public funding for voluntary, universal preschool and requires participating preschools to sign a nondiscrimination agreement. This agreement mandates that preschools offer equal enrollment opportunities regardless of characteristics such as race, religious affiliation, sexual orientation, gender identity, income, or disability. The plaintiffs—two Catholic parishes, their preschools, the Archdiocese of Denver, and two parents—challenged the nondiscrimination requirement, arguing that it conflicted with their religious beliefs, particularly regarding sexual orientation and gender identity, and violated their rights under the First Amendment.The United States District Court for the District of Colorado held a three-day bench trial. The court found that the nondiscrimination requirement did not violate the First Amendment, denied the plaintiffs’ request for injunctive relief, and dismissed the Archdiocese for lack of standing. However, the court did enjoin the state from enforcing the nondiscrimination requirement as to religious affiliation for as long as a congregation preference existed, a ruling not challenged on appeal. The plaintiffs appealed the denial of injunctive relief and the dismissal of the Archdiocese.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The Tenth Circuit held that the nondiscrimination requirement is a neutral law of general applicability and does not target religious status or use. The court found no evidence of religious hostility or individualized exemptions that would undermine general applicability. The court also rejected the plaintiffs’ expressive association claim, distinguishing the facts from Supreme Court precedents. Applying rational basis review, the court concluded that the requirement is rationally related to the legitimate government interest of ensuring equal access to preschool. The district court’s denial of injunctive relief was affirmed. View "St. Mary Catholic v. Roy" on Justia Law

A nonprofit organization sought access to confidential court records from child protective and adoption proceedings involving a young girl who died after being placed in foster care and later adopted. The girl was reported missing in 2021, and her death was confirmed in 2023. The records also contained information about her siblings. The siblings, through their counsel, did not object to disclosure as long as their identities were protected through redactions. The Department of Human Services and the adoptive father opposed disclosure, arguing that the records were confidential and that redactions would not sufficiently protect privacy.The Family Court of the First Circuit denied the request, reasoning that releasing redacted records would be misleading and would not serve the public interest in understanding the response of agencies and the court to child abuse and neglect. The court concluded that the records should remain sealed, citing concerns about the completeness and potential for misunderstanding of the redacted information.The Supreme Court of the State of Hawaiʻi reviewed the case and held that, under Hawaiʻi Revised Statutes §§ 587A-40 and 578-15, public access to confidential child protective and adoption records is permitted when a foster child is missing, has suffered a near fatality, been critically injured, or has died, provided that information about living siblings is redacted to protect their privacy. The court overruled prior precedent to the extent it limited disclosure to only those purposes that further the best interests of the child, clarifying that a “legitimate purpose” for disclosure can exist independently. The court ordered the release of the redacted records and provided guidance for future requests, affirming the family court’s authority to require agencies to prepare redacted versions for public access. View "Public First Law Center v. Viola" on Justia Law

Patrick Jones Jr. was hired as a probationary deputy sheriff by the Lake County Sheriff’s Office and sent to a police training academy. During his training, Jones obtained a document from his girlfriend, believing it to be a study guide, and offered to share it with classmates. The document was actually a cheat sheet for a prior version of the Illinois state law enforcement exam. After an investigation by the training institute, which concluded Jones likely did not understand the document’s true nature, the Sheriff’s Office nonetheless terminated his employment. The termination letter, authored by Undersheriff Lawrence Oliver, cited Jones’s conduct as violating the office’s code of conduct and was distributed internally and to the office’s Merit Commission. Jones later struggled to find new law enforcement employment, attributing this difficulty to the termination letter.Jones filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the termination letter was defamatory and that it deprived him of occupational liberty in violation of the Fourteenth Amendment. The district court granted summary judgment for the Sheriff’s Office and Undersheriff Oliver, finding that Jones failed to show it was virtually impossible for him to find new employment and that the statements in the letter were either true or opinion, and that Oliver was entitled to absolute immunity under Illinois law.The United States Court of Appeals for the Seventh Circuit affirmed. The court held that the Sheriff’s Office was not a proper defendant under 42 U.S.C. § 1983 because Jones did not allege a policy or custom as required for municipal liability. The court further held that Jones’s occupational liberty claim failed because there was no evidence that Undersheriff Oliver publicly disclosed the termination letter. Finally, the court held that Undersheriff Oliver was entitled to absolute immunity under Illinois law for statements made within the scope of his official duties. View "Jones v. Lake County Sheriff's Office" on Justia Law

After the sudden death of an Alameda County Supervisor in 2021, the Board of Supervisors appointed David Kyle Brown, the former chief of staff to the late supervisor, to fill the vacancy for District 3. At the time of his appointment, Brown had been living in Contra Costa County but moved to Oakland, within District 3, shortly before his appointment. Plaintiffs, including the Alameda County Taxpayers’ Association and several individuals, challenged Brown’s eligibility to serve, arguing he failed to meet both a one-year prior residency requirement under the Alameda County Administrative Code and a 30-day prior residency requirement under state law. They also contended that Brown did not satisfy the continuous residency requirement during his term, asserting he never became a true resident of the district.The Superior Court of Alameda County first overruled Brown’s demurrer and held a hearing on the merits of the prior residency issue. The court found that neither the county nor state code imposed a prior residency requirement on appointees filling a board vacancy, ruling in Brown’s favor. After Brown’s term ended, the court determined that the continuous residency issue was moot, as Brown was no longer in office, and entered judgment for Brown. Plaintiffs appealed, arguing the issues were of public importance and that the trial court erred in its rulings and case management.The California Court of Appeal, First Appellate District, Division Four, held that the prior residency requirements cited by plaintiffs do not apply to appointments made to fill board vacancies. However, the court found that the continuous residency requirement does apply and that there are unresolved factual questions regarding whether Brown satisfied this requirement during his term. The court affirmed the trial court’s judgment in part, reversed in part, and remanded for further proceedings on the continuous residency issue. View "People ex rel. Alameda County Taxpayers' Assn. v. Brown" on Justia Law

A woman who immigrated from China to the United States and later became a U.S. citizen founded an educational institution that participated in a Department of Defense tuition program. In 2010, the FBI began investigating her for statements made on immigration forms, conducting interviews, searches, and seizing personal and business materials. Although the U.S. Attorney’s Office ultimately declined to file charges, Fox News later published reports about her, including confidential materials from the FBI investigation. These reports cited anonymous sources and included documents and photographs seized during the FBI’s search. Following the reports, the Department of Defense terminated her institution’s participation in the tuition program, resulting in significant financial losses.She filed a lawsuit in the United States District Court for the District of Columbia against the FBI and other federal agencies, alleging violations of the Privacy Act due to the unauthorized disclosure of her records. During discovery, she was unable to identify the source of the leak despite extensive efforts. She then subpoenaed a Fox News journalist, who authored the reports, to reveal her confidential source. The journalist invoked a qualified First Amendment reporter’s privilege. The district court found that the plaintiff had met the requirements to overcome this privilege—demonstrating both the centrality of the information to her case and exhaustion of alternative sources—and ordered the journalist to testify. When the journalist refused, the court held her in civil contempt.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s orders. The appellate court held that, under its precedents, a qualified First Amendment reporter’s privilege may be overcome in civil cases if the information sought is crucial to the case and all reasonable alternative sources have been exhausted. The court also declined to recognize a broader federal common law reporter’s privilege. View "Chen v. FBI" on Justia Law

The case concerns the approval of a 32-mile natural gas pipeline intended to supply fuel to a new natural-gas turbine that will replace one of two coal-fired units at the Cumberland Fossil Plant in Tennessee. The Tennessee Valley Authority (TVA), a federal agency, decided to retire the coal units and replace one with a gas turbine, which is expected to reduce greenhouse gas emissions. The Federal Energy Regulatory Commission (FERC) approved the pipeline after preparing a detailed environmental impact statement. The Sierra Club and Appalachian Voices challenged this approval, arguing that FERC’s decision violated the National Environmental Policy Act (NEPA) and the Natural Gas Act.Previously, FERC issued a certificate of public convenience and necessity for the pipeline, finding that market need was established by TVA’s long-term agreement to purchase all pipeline capacity and that the project’s benefits outweighed its harms. FERC also credited the pipeline with enabling a net reduction in emissions due to the coal-to-gas transition. After the Sierra Club requested rehearing, FERC clarified that only one coal unit would be replaced but maintained its approval. The Sierra Club then petitioned the United States Court of Appeals for the District of Columbia Circuit for review.The United States Court of Appeals for the District of Columbia Circuit denied the petitions. The court held that FERC’s approval complied with NEPA and the Natural Gas Act. It found that FERC reasonably analyzed downstream emissions, properly considered the no-action alternative, and was not required to analyze the pipeline and power plant as connected actions because FERC lacked regulatory authority over power generation. The court also held that FERC’s reliance on TVA’s precedent agreement established market need and that FERC’s public interest balancing was reasonable. The court emphasized that, following recent Supreme Court precedent, judicial review of NEPA compliance is highly deferential. View "Sierra Club v. Federal Energy Regulatory Commission" on Justia Law

An independent natural gas producer contracted with a pipeline operator to secure firm transportation capacity through an expansion project, which involved adding new compressor stations to an existing pipeline segment. The producer agreed to pay for the construction of these facilities and the applicable fuel and power charges. The pipeline operator recoups fuel costs through rates based on the amount of gas shipped, with costs increasing exponentially as more gas is transported. After the expansion, the pipeline operator implemented a two-tier fuel rate system: the producer was always charged the highest marginal fuel rate, as if its gas was the last and most expensive to move through the pipeline, while all other shippers paid an average rate.Initially, the Federal Energy Regulatory Commission (FERC) approved the pipeline operator’s tariff, including the two-tier rate structure, and later reaffirmed this approach when the producer protested after experiencing significantly higher fuel rates compared to other shippers. The producer argued that the rate structure was unduly discriminatory and not “just and reasonable” under the Natural Gas Act. An administrative law judge upheld the rates, and FERC affirmed, reasoning that the producer, as the “but for” cause of the expansion, should bear the highest marginal costs to prevent subsidization by other shippers.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that FERC’s approval of the two-tier fuel rate was arbitrary and capricious. The court found that perpetually assigning the producer the highest marginal fuel rate was disconnected from the actual costs imposed by its use of the pipeline and violated the principle of cost causation. The court granted the producer’s petition for review, vacated FERC’s order, and remanded for further proceedings to establish a just and reasonable rate consistent with cost-causation principles. View "Antero Resources Corporation v. Federal Energy Regulatory Commission" on Justia Law

An individual who had lived in the United States since 1993 became the subject of removal proceedings after overstaying his visa. During these proceedings, he sought various forms of relief, while the government opposed his applications by presenting evidence and testimony linking him to high-level terrorists. The individual subsequently submitted a Freedom of Information Act (FOIA) request to the Federal Bureau of Investigation (FBI) for his file. The FBI located a substantial volume of potentially responsive records but withheld most of them, citing law enforcement concerns. The requester then filed suit to compel disclosure.The United States District Court for the District of Columbia initially denied the FBI’s motion for summary judgment without prejudice, requiring updated information on whether enforcement proceedings were still pending or reasonably anticipated, and more detail regarding the segregability of non-exempt information. After the FBI submitted updated public and ex parte declarations confirming that investigations remained ongoing and providing further explanation about segregability, the district court granted summary judgment in favor of the FBI. The court found that the records were compiled for law enforcement purposes, that disclosure could reasonably be expected to interfere with ongoing or anticipated enforcement proceedings, and that no meaningful non-exempt information was reasonably segregable.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the grant of summary judgment de novo. The appellate court held that the FBI met its burden under FOIA Exemption 7(A) by showing the records were compiled for law enforcement purposes and that disclosure could reasonably be expected to interfere with pending or reasonably anticipated enforcement proceedings. The court also affirmed the district court’s finding that no reasonably segregable non-exempt information existed. Accordingly, the appellate court affirmed the district court’s judgment. View "Farahi v. Federal Bureau of Investigation" on Justia Law