Justia Government & Administrative Law Opinion Summaries

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law

A New York wine retailer, Jean Paul Weg LLC, and its owner, Lars Neubohn, challenged New Jersey's regulations that require wine retailers to have a physical presence in the state and to purchase their products from New Jersey licensed wholesalers. These regulations prevent the retailer from directly shipping wine to New Jersey customers. The plaintiffs argued that these requirements violate the Commerce Clause by discriminating against out-of-state economic interests.The United States District Court for the District of New Jersey denied the plaintiffs' motion for summary judgment and granted summary judgment in favor of the defendants, including the Director of the New Jersey Division of Alcoholic Beverage Control and the Attorney General of New Jersey. The District Court found that New Jersey's regulations were justified by legitimate local purposes, such as ensuring alcohol sold to New Jersey consumers passes through the state's three-tier system and facilitating inspections to ensure compliance with regulations.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit held that New Jersey's regulations, while discriminatory in effect, were justified on legitimate nonprotectionist grounds. The court found that the physical presence requirement facilitates inspections and investigations, while the wholesaler purchase requirement helps quickly identify sources of contamination and facilitates product recalls. Additionally, the court determined that these regulations are essential features of New Jersey's three-tier system of alcohol regulation, which is "unquestionably legitimate" under the Twenty-first Amendment. Therefore, the challenged regulations were upheld as constitutional. View "Jean-Paul Weg LLC v. Director of the New Jersey Division of Alcoholic Beverage Control" on Justia Law

Shanta Webster filed a complaint in the Grenada County Circuit Court against the University of Mississippi Medical Center-Grenada (UMMC-Grenada) and Drs. Aimee Watts and Kimberly Farmer, alleging medical negligence in the performance of a hysterectomy and post-operative care. Webster served the complaint to Dr. Watts, Dr. Farmer, and Dodie McElmurry, the CEO of UMMC-Grenada. The defendants requested an extension to answer the complaint and later claimed immunity under the Mississippi Tort Claims Act (MTCA). Webster argued that service of process was proper under Rule 4(d)(8) of the Mississippi Rules of Civil Procedure.The Grenada County Circuit Court dismissed the complaint, ruling that service of process was improper because it was not made to the Attorney General as required by Rule 4(d)(5) for state institutions. Webster appealed the dismissal, maintaining that UMMC-Grenada is a community hospital and that service on the CEO was sufficient.The Supreme Court of Mississippi reviewed the case de novo and upheld the trial court's decision. The court found that UMMC-Grenada is not a separate entity but a part of UMMC, a state institution. Therefore, service of process should have been made to the Attorney General under Rule 4(d)(5). Webster failed to serve the Attorney General within the 120-day period required by Rule 4(h), rendering the service invalid. Additionally, the court noted that Drs. Watts and Farmer, acting within the scope of their employment, were immune from personal liability under the MTCA.The Supreme Court of Mississippi affirmed the trial court's order of dismissal, concluding that proper service of process was not effected, and the individual defendants were immune from liability. View "Webster v. University of Mississippi Medical Center Grenada" on Justia Law

Appellants, including GL B Energy Corporation and others, were accused of transshipping xanthan gum from China through India to evade antidumping duties imposed by the U.S. Department of Commerce. Customs and Border Protection (CBP) initiated an investigation based on allegations from CP Kelco U.S., a domestic producer, and found substantial evidence that the xanthan gum was of Chinese origin and subject to antidumping duties. Customs applied adverse inferences against the manufacturers for not cooperating with information requests, concluding that the merchandise was transshipped to evade duties.The United States Court of International Trade (CIT) reviewed the case and affirmed Customs' determinations. The CIT dismissed claims related to finally liquidated entries for lack of subject matter jurisdiction, as the importers failed to timely appeal the denial of their protests. The CIT also denied the remaining motions for judgment on the agency record, finding that Customs' determinations were supported by substantial evidence and were not arbitrary or capricious.The United States Court of Appeals for the Federal Circuit reviewed the case. The court agreed with the CIT that Customs' evasion determinations were supported by substantial evidence and were in accordance with the law. The court also found that the CIT had jurisdiction to review the evasion determinations, even for finally liquidated entries, based on the precedent set in Royal Brush Mfg., Inc. v. United States. However, the court affirmed the CIT's decision, noting that the CIT would have denied the motions for judgment on the agency record for the same reasons stated for the other entries. The court concluded that Customs' evasion determinations were lawful and supported by substantial evidence. View "ALL ONE GOD FAITH, INC. v. US " on Justia Law

The petitioner, Lin Luo, sought review of a final order from the Office of Administrative Hearings (OAH) that determined her ineligible for unemployment benefits from April 5, 2023, to June 28, 2023. Luo was terminated from her position at the American Chemical Society (ACS) and received post-termination payments under an Agreement and General Release. The OAH administrative law judge (ALJ) classified these payments as severance pay, which disqualified her from receiving unemployment benefits. Luo argued that the payments were settlement payments for sexual harassment claims, not severance pay.The Department of Employment Services (DOES) initially found Luo ineligible for benefits for a slightly different period. Luo appealed to OAH, where the ALJ held a hearing and excluded Luo's evidence of her harassment claims, citing the parol evidence rule. The ALJ concluded that the Agreement's language unambiguously indicated the payments were severance pay, based on Luo's years of service and lack of advance notice of termination. The ALJ also noted that the Agreement included a release of claims against ACS and found that Luo signed the Agreement without fraud, duress, or mutual mistake.The District of Columbia Court of Appeals reviewed the case and found that the ALJ erred in not considering parol evidence regarding the nature of the payments. The court noted that the parol evidence rule does not preclude evidence showing that factual recitals in an agreement are untrue. The court concluded that the ALJ should have considered Luo's testimony and evidence about her harassment claims to determine the parties' intent regarding the payments. The court vacated the OAH orders and remanded the case for further proceedings to consider this evidence. View "Luo v. District of Columbia Department of Employment Services" on Justia Law

Gerry Serrano, a police officer for the City of Santa Ana, took a leave of absence to serve as president of the Santa Ana Police Officers Association. The Public Employees’ Retirement System (CalPERS) determined that certain special pay additives Serrano received before and during his service as Association president could not be included in his pension. The Administrative Board of CalPERS and the Superior Court of Sacramento County affirmed the exclusion of most of these pay additives from Serrano’s pension. Serrano appealed, arguing that Government Code section 3558.8 mandates he cannot lose any compensation, including pensionable compensation, while serving as the Association president. He also challenged the specific exclusion of a confidential premium and holiday pay from his pensionable compensation.The Superior Court of Sacramento County denied Serrano’s petition for writ of administrative mandamus, which sought to vacate the Board’s decision and include all pay additives in his retirement calculation. Serrano then appealed to the California Court of Appeal, Third Appellate District.The California Court of Appeal, Third Appellate District, affirmed the lower court’s decision. The court held that section 3558.8 did not require the compensation Serrano earned as a police sergeant to be entirely pensionable while he served as Association president. The court concluded that the confidential premium was not pensionable because it constituted nonpensionable overtime and did not meet the regulatory definition for the confidentiality premium. Additionally, the court found that Serrano’s holiday pay was not pensionable because he was not required to work on holidays, as required by the relevant regulation. The court’s decision was based on the interpretation of the Retirement Law and the specific definitions and requirements for pensionable compensation under that law. View "Serrano v. Public Employees' Retirement System" on Justia Law

In the early morning of November 1, 2019, a group of law enforcement officers, including Task Force Officer (TFO) Clarence Belton and Charlotte-Mecklenburg Police Officer Heather Loveridge, attempted to execute a search warrant at the house of a suspect, Larry McConneyhead, in Charlotte, North Carolina. During the operation, McConneyhead fled into his house, and a confrontation ensued. TFO Belton was accidentally shot by Officer Loveridge, who mistook him for the suspect. Belton suffered severe injuries, leading to multiple surgeries and permanent disability.The case was initially filed in North Carolina state court and then removed to the United States District Court for the Western District of North Carolina. Belton alleged excessive force under 42 U.S.C. § 1983 and several state law claims against Officer Loveridge and the City of Charlotte. Officer Loveridge moved for summary judgment, asserting qualified immunity for the federal claim and public officers’ immunity for the state claims. The district court denied her motion, citing genuine disputes of material fact regarding the circumstances of the shooting.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court failed to conduct the proper analysis for determining qualified immunity, which requires identifying the specific constitutional right violated and whether that right was clearly established at the time of the incident. The Fourth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to apply the correct legal standards for qualified immunity and public officers’ immunity. View "Belton v. Loveridge" on Justia Law

John Lowry, a harbor patrol officer, suffered physical and psychiatric injuries, including PTSD, from a workplace accident. His psychiatrist deemed him unfit to return to work, and the Port San Luis Harbor District (the District) indicated that his only option was retirement. Lowry applied for disability retirement, but the District denied his application, stating insufficient information to determine disability. The California Public Employees’ Retirement System (CalPERS) also denied his application, and the District terminated his employment, claiming he voluntarily resigned, which was later admitted to be untrue.The trial court granted summary judgment in favor of the District, concluding that Lowry was not eligible for relief under the California Fair Employment and Housing Act (FEHA) because he could not perform his essential job duties with or without reasonable accommodations. The court found that disability retirement does not qualify as a term, condition, or privilege of employment under FEHA.The California Court of Appeal, Second Appellate District, Division Six, affirmed the trial court's decision. The court held that the denial of disability retirement payments is not an adverse employment action under FEHA. Disability retirement payments serve as income replacement for employees who can no longer work and do not facilitate continued employment, job performance, or advancement opportunities. The court concluded that an individual who is not a qualified employee cannot bring a disability discrimination claim under FEHA for the denial of disability retirement payments. The judgment in favor of the District was affirmed. View "Lowry v. Port San Luis Harbor Dist." on Justia Law

The complainant, John Ward, filed a complaint with the Commission on Human Rights and Opportunities (CHRO) alleging that the City of Stamford discriminated against him based on his veteran status and disability. The CHRO found reasonable cause and certified the complaint to the Office of Public Hearings (OPH). During the public hearing, Ward moved to amend his complaint to include a claim for denial of reasonable accommodations. The human rights referee granted the motion over the city's objection.The city filed an interlocutory administrative appeal with the Superior Court, arguing that the CHRO lacked jurisdiction to hear the amended complaint without a reasonable cause finding. The CHRO and Ward moved to dismiss the appeal, contending that interlocutory rulings are not appealable under General Statutes § 46a-94a (a) and that the statutory requirements for an interlocutory appeal under § 4-183 (b) were not met. The trial court denied the motions to dismiss, finding that the referee's ruling was a final decision under § 4-183 (a).The Supreme Court of Connecticut reviewed the case and concluded that the referee's ruling was not a final decision under § 4-183 (a) because it did not terminate any aspect of the case or determine any rights or obligations. The court also determined that § 46a-94a (a) allows for interlocutory appeals under § 4-183 (b), but the city's appeal did not meet the criteria for such an appeal because postponement would not result in an inadequate remedy. The court reversed the trial court's decision and remanded with direction to grant the motions to dismiss the city's appeal. View "Stamford v. Commission on Human Rights& Opportunities" on Justia Law

A hospital in Siskiyou County, California, filed a lawsuit against the County of Siskiyou and other defendants, challenging the practice of bringing individuals with psychiatric emergencies to its emergency department under the Lanterman-Petris-Short (LPS) Act. The hospital argued that it was not equipped or licensed to provide the necessary psychiatric care and sought to prevent the county from bringing such patients to its facility unless they had a physical emergency condition. The hospital also sought reimbursement for the costs associated with holding these patients.The Siskiyou County Superior Court denied the hospital's motion for a preliminary injunction, which sought to stop the county from bringing psychiatric patients to its emergency department. The court found that the hospital had not demonstrated a likelihood of success on the merits and that the burden on the county and the potential harm to the patients outweighed the hospital's concerns.The hospital's complaint included several causes of action, including violations of Medicaid laws, disability discrimination laws, mental health parity laws, and section 17000 of the Welfare and Institutions Code. The hospital also alleged breach of an implied-in-fact contract for the costs incurred in providing post-stabilization services to psychiatric patients. The trial court sustained demurrers to the complaint without leave to amend, finding that the hospital failed to identify any clear legal mandate that the county or the Department of Health Care Services had violated.The California Court of Appeal, Third Appellate District, affirmed the trial court's judgment of dismissal. The appellate court concluded that the hospital had not identified any mandatory and ministerial duty that the county or the department had violated, which is necessary to obtain a writ of mandate. The court also found that the hospital's breach of contract claim failed because there were no allegations of mutual consent to an implied contract. Consequently, the hospital's appeal from the denial of its motion for a preliminary injunction was dismissed as moot. View "Siskiyou Hospital v. County of Siskiyou" on Justia Law