Justia Government & Administrative Law Opinion Summaries

Two elderly individuals, Ms. Penelope Lamle and Ms. Maxine Houston, applied for Medicaid but faced delays and additional questions from the Oklahoma Department of Human Services, allegedly directed by attorney Susan Eads. They refused to answer these questions and subsequently sued, seeking an expedited decision, payment of Medicaid benefits, and damages. Both applicants died during the litigation, and their estates were substituted as parties in the appeal.The United States District Court for the Western District of Oklahoma dismissed the action with prejudice, citing the plaintiffs' failure to state a valid claim. However, the court was unaware that the applicants had died while the action was pending.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the claims for an injunction became moot when the agency denied benefits and the applicants died. The court noted that the requested relief would no longer benefit the estates, as the Oklahoma Department of Human Services had already denied the applications. The court also held that the Eleventh Amendment barred the requested retrospective relief. Consequently, the court remanded the case to the district court with instructions to vacate the judgment on the claim for a prospective injunction and dismiss it without prejudice.Regarding the claim against Ms. Eads in her individual capacity, the Tenth Circuit held that she was entitled to qualified immunity. The court found that the plaintiffs did not allege facts showing the violation of a clearly established right. As a result, the court affirmed the dismissal with prejudice of the claim for damages against Ms. Eads. View "Lamle v. Eads" on Justia Law

In 2019, the Rhode Island Department of Corrections (DOC) implemented changes to its Absenteeism Management Program (AMP), citing abuse of the existing sick-time policy. The changes included new discipline tracks, sanctions for absenteeism, stricter sick note requirements, and closer scrutiny of pattern sick time use. The Rhode Island Brotherhood of Correctional Officers (RIBCO) requested bargaining over these changes, which the DOC refused, leading RIBCO to file an unfair labor practice charge.The Rhode Island State Labor Relations Board (SLRB) found that the DOC had committed an unfair labor practice by making substantial changes to working conditions without bargaining. The board rejected the DOC's defenses, including the argument that the changes were within the director’s statutory authority and the management-rights clause of the collective bargaining agreement (CBA).The DOC appealed to the Superior Court, which reversed the SLRB's decision. The Superior Court found that the board's decision was not supported by substantial evidence and that the changes were within the DOC director’s statutory authority under Rhode Island law.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the SLRB's decision was not supported by reliable, probative, and substantial evidence. It also agreed that the changes to the AMP were within the DOC director’s statutory authority under sections 42-56-10(2), (5), and (7) of the Rhode Island General Laws, which grant the director broad discretion in managing the department, maintaining safety and order, and disciplining employees. Thus, the DOC was not obligated to bargain over the AMP changes. View "State of Rhode Island v. Rhode Island State Labor Relations Board" on Justia Law

A national consumer advocate law firm (C Co.) and its affiliate (S Co.) providing administrative support services sought injunctive and declaratory relief against the Department of Banking. The Department had initiated an administrative enforcement action against S Co. for allegedly engaging in unlicensed debt negotiation activities. The plaintiffs argued that S Co. was exempt from licensing requirements under a presumption established in a prior case (Persels & Associates, LLC v. Banking Commissioner), which holds that attorneys providing debt negotiation services as part of their legal practice fall under the exclusive regulation of the Judicial Branch.The trial court denied the Department's motion to dismiss the plaintiffs' action, concluding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention on whether the Persels presumption applied to S Co. The Department appealed, arguing that the Commissioner of Banking should first determine whether the presumption applied.The Supreme Court of Connecticut affirmed the trial court's decision, holding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention. The court reasoned that the Commissioner of Banking lacks the expertise to determine whether the Persels presumption applies, as this involves assessing whether the activities in question constitute the practice of law, which falls under the exclusive authority of the Judicial Branch. The court emphasized that allowing the commissioner to make this determination would violate the constitutional separation of powers. Therefore, the plaintiffs could seek declaratory and injunctive relief in the trial court without waiting for the commissioner to resolve the issue. View "Commonwealth Servicing Group, LLC v. Dept. of Banking" on Justia Law

Badlia Brothers, LLC, a check-cashing business, cashed 15 checks issued by the State of Maryland. These checks had already been paid by the State before Badlia presented them for payment. Some checks were deposited using a mobile app, creating "substitute checks," and were then fraudulently or negligently presented to Badlia. Others were reported lost or stolen, leading the State to issue stop payment orders and replacement checks, which were also cashed by Badlia. Badlia accepted the checks without knowledge of prior payments and sought payment from the State, which refused.Badlia filed complaints in the District Court of Maryland, claiming the right to enforce the checks as a holder in due course. The court consolidated the cases, ruled that the State enjoyed qualified immunity, and dismissed the cases. The Circuit Court for Baltimore City reversed, holding that a check is a contract, and thus, the State had waived sovereign immunity. On remand, the District Court found that Badlia was a holder in due course entitled to enforce the checks. The Circuit Court affirmed, and the State petitioned for certiorari.The Supreme Court of Maryland reviewed the case and held that a check is a contract for purposes of the State’s waiver of sovereign immunity under § 12-201(a) of the State Government Article. The court affirmed the Circuit Court's decision, concluding that the State has waived sovereign immunity for claims by a holder in due course seeking payment on an authorized State-issued check. View "Comptroller v. Badlia Brothers, LLC" on Justia Law

The case involves Pueo Kai McGuire, who filed a 42 U.S.C. § 1983 action against the County of Hawai'i, the county prosecutor, and three deputy prosecutors, alleging violations of his constitutional rights, including malicious prosecution. The United States District Court for the District of Hawai'i certified a question to the Supreme Court of the State of Hawai'i to determine whether, under Hawai'i law, a county Prosecuting Attorney and/or Deputy Prosecuting Attorney acts on behalf of the county or the state when preparing to prosecute and/or prosecuting criminal violations of state law.The United States District Court for the District of Hawai'i reviewed the case and found the matter of whether county prosecutors act on behalf of the county or the state to be unsettled under Hawai'i law. Consequently, the court certified this question to the Supreme Court of the State of Hawai'i for clarification.The Supreme Court of the State of Hawai'i held that, under Hawai'i law, county prosecuting attorneys and their deputies act on behalf of the county when preparing to prosecute or prosecuting state law offenses. The court's decision was based on an analysis of the historical and current legal framework governing prosecutorial authority in Hawai'i, including the Hawai'i Constitution, state statutes, and county charters. The court emphasized that county prosecutors are primarily responsible for initiating and conducting criminal prosecutions within their county jurisdictions, with the state attorney general retaining only residual authority to intervene in compelling circumstances. The court declined to extend state sovereign immunity to county prosecutors, affirming that they are suable persons under 42 U.S.C. § 1983. View "McGuire v. County of Hawai'i" on Justia Law

An off-duty St. Louis Police Officer, Milton Green, was mistakenly shot by Officer Christopher Tanner during a pursuit of a suspect who had fired at police officers. Green filed a lawsuit under 42 U.S.C. § 1983 against Tanner and the City of St. Louis, alleging Fourth and Fourteenth Amendment violations and state law claims. The district court granted summary judgment in favor of the defendants, concluding that Tanner did not violate Green’s constitutional rights and that official immunity barred the state-law claims. The court also denied Green’s motions to alter or amend the judgment and to submit newly discovered evidence.The United States District Court for the Eastern District of Missouri granted summary judgment to the defendants, finding that Tanner’s actions were reasonable under the circumstances and that there was no constitutional violation. The court also ruled that Green’s Monell claim against the City failed due to the lack of an underlying constitutional violation and that official immunity protected Tanner from the state-law claims. Green’s motions to alter or amend the judgment and to reopen discovery were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that Tanner’s use of force was objectively reasonable given the circumstances, which involved a rapidly evolving and dangerous situation. The court also upheld the dismissal of the Monell claims against the City, as there was no constitutional violation by Tanner. Additionally, the court affirmed the denial of Green’s post-judgment motions and the dismissal of the state-law battery claims, agreeing that official immunity applied. View "Green v. City of St. Louis" on Justia Law

Clarios, LLC (Clarios) purchased an industrial site in 2006, for which the seller had executed a remediation plan under the Industrial Site Recovery Act (ISRA) and placed funds in trust for future remediation. In 2007, Clarios ceased operations and sought a Remediation in Progress Waiver (RIP Waiver) from the New Jersey Department of Environmental Protection (DEP), which was granted with the condition that the DEP reserved the right to enforce ISRA obligations in the future. Clarios sold the site in 2011, and the new owner, DeNovo, assumed remediation responsibilities. By 2021, the remediation trust was depleted, and the site was out of compliance. In April 2022, the DEP rescinded Clarios’s RIP Waiver due to non-compliance and depletion of funds.Clarios requested an adjudicatory hearing, arguing that the rescission without notice or a hearing violated its due process rights. The DEP denied the request, stating that rescission did not entitle Clarios to a hearing under the relevant regulations. Clarios appealed, and the Appellate Division ruled in favor of the DEP, holding that Clarios did not have a protected property interest in the RIP Waiver. The court found that Clarios’s expectation of continued suspension of remediation obligations was not based on any statutory or regulatory provisions but rather on a unilateral expectation.The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division’s decision. The Court held that the DEP’s initial grant of the RIP Waiver did not create a property interest in the continued suspension of Clarios’s remediation obligations. The Court found that neither the controlling statutes and regulations nor a mutually explicit understanding between the parties provided an entitlement to the indefinite continuance of the waiver. The governing laws and agency materials anticipated the DEP’s ability to enforce remediation obligations in the future, and thus, rescission of the RIP Waiver without a hearing did not violate Clarios’s due process rights. View "In re Appeal of the New Jersey Department of Environmental Protection's September 6, 2022 Denial of Request for Adjudicatory Hearing" on Justia Law

The United States District Court for the District of Massachusetts issued a temporary restraining order (TRO) on March 10, 2025, preventing the Government from terminating various education-related grants. The order also required the Government to pay past-due grant obligations and continue paying future obligations. The District Court concluded that the respondents were likely to succeed on the merits of their claims under the Administrative Procedure Act (APA).The Government filed an application to vacate the District Court's order on March 26, 2025, which was extended on March 24, 2025. The application was presented to Justice Jackson and referred to the Supreme Court. The Supreme Court noted that the District Court's order had characteristics of a preliminary injunction, making it appealable. The Government argued that the District Court lacked jurisdiction to order the payment of money under the APA, as the APA's waiver of sovereign immunity does not apply to claims seeking money damages or to orders enforcing contractual obligations to pay money.The Supreme Court of the United States granted the Government's application to stay the District Court's order pending the appeal in the United States Court of Appeals for the First Circuit and any subsequent petition for a writ of certiorari. The Court found that the respondents had not refuted the Government's claim that it would be unlikely to recover the grant funds once disbursed and that respondents would not suffer irreparable harm while the TRO is stayed. The stay will terminate automatically if certiorari is denied or upon the sending down of the judgment of the Supreme Court if certiorari is granted. The Chief Justice would have denied the application. View "Department of Education v. California" on Justia Law

The case involves a dispute over the Tennessee Department of Environment and Conservation’s (TDEC) issuance of a water quality certification to Tennessee Gas Pipeline Company (TGP) for the construction and operation of a 32-mile natural gas pipeline in Tennessee. The pipeline would cross over one hundred bodies of water and require drilling across rocky terrain. Environmental groups Sierra Club and Appalachian Voices argue that TDEC failed to properly assess TGP’s application and ensure that the pipeline would not cause significant environmental damage.The lower court, TDEC, issued the water quality certification to TGP, authorizing temporary and permanent impacts to various water bodies and wetlands. TDEC imposed several conditions on TGP to minimize environmental disruption, including selecting the least impactful trenching techniques and obtaining written authorization before using controlled blasting. Petitioners filed a timely Petition for Review in the United States Court of Appeals for the Sixth Circuit, arguing that TDEC’s issuance of the certification violated the Administrative Procedure Act (APA).The United States Court of Appeals for the Sixth Circuit reviewed the case and found that TDEC did not violate the APA. The court held that TDEC adequately evaluated the water quality certification application and reasonably explained its decision-making process regarding waterbody crossings, rock removal methodology, downstream sedimentation, trench excavation, and baseline conditions of waterbodies. The court concluded that TDEC’s actions were not arbitrary, capricious, or inconsistent with its regulations. Consequently, the court denied the Petition for Review. View "Sierra Club v. Tennessee Department of Environment and Conservation" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law