Justia Government & Administrative Law Opinion Summaries

Michael Solondz, a commercial airline pilot, was diagnosed with anxiety and prescribed mirtazapine after experiencing side effects from another medication. Mirtazapine effectively managed his anxiety without significant side effects. Solondz sought medical clearance from the Federal Aviation Administration (FAA) to resume flying, but the FAA categorically disallows pilots from flying while taking mirtazapine, despite allowing conditional approvals for other antidepressants.The FAA denied Solondz's request for a Special Issuance medical certificate multiple times, citing his use of mirtazapine, anxiety, sleep apnea, optic neuritis, and a history of atrial fibrillation. Solondz provided evidence that his conditions were well-managed and that mirtazapine did not cause significant side effects. The FAA's final denial letter reiterated these reasons and added a concern about a potential malignant melanoma diagnosis, which Solondz disputed.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the FAA failed to provide a reasonable explanation for categorically disallowing pilots taking mirtazapine from obtaining medical certification. The court noted that the FAA's process for conditionally approving other antidepressants involves a six-month waiting period and individualized medical assessments, which could also apply to mirtazapine.The court vacated the FAA's final denial letter and remanded the case for further explanation. The court emphasized that the FAA must articulate a clear rationale for its policy and avoid offering explanations that contradict the evidence. The petition for review was granted, and the case was remanded to the FAA for further proceedings consistent with the court's opinion. View "Solondz v. FAA" on Justia Law

A group of entities managing a university hospital and a union representing the hospital’s service workers have been negotiating a successor agreement since 2016. The hospital proposed three key changes: granting itself unilateral control over employment terms, imposing a no-strike clause, and eliminating binding arbitration. The National Labor Relations Board (NLRB) found that these proposals collectively constituted bad faith bargaining, as they would leave union employees worse off than if no contract existed.An Administrative Law Judge (ALJ) initially sustained the complaint against the hospital, concluding that the hospital violated Sections 8(a)(1) and 8(a)(5) of the National Labor Relations Act (NLRA) by bargaining in bad faith. The ALJ found that the hospital’s proposals, including a restrictive grievance-arbitration procedure and a broad management rights clause, indicated an intent to undermine the bargaining process. The hospital’s regressive bargaining tactics further supported this conclusion.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld the NLRB’s findings, agreeing that the hospital’s conduct amounted to bad faith surface bargaining. The court found substantial evidence supporting the NLRB’s conclusion that the hospital’s proposals, taken together, would strip the union of its representational role and leave employees with fewer rights than they would have without a contract. The court also upheld the NLRB’s procedural decisions, including vacating an earlier decision due to a board member’s financial conflict of interest and seating a new member for the final decision.The court denied the hospital’s petition for review and granted the NLRB’s cross-application for enforcement, affirming the NLRB’s order for the hospital to recognize and bargain with the union, rescind unilateral changes, compensate affected employees, and submit periodic reports on bargaining progress. View "District Hospital Partners, L.P. v. NLRB" on Justia Law

Radio Communications Corporation (RCC), a telecommunications and media company, petitioned for review of a final order issued by the Federal Communications Commission (FCC) implementing the Low Power Protection Act (LPPA). The LPPA allows low power television (LPTV) stations to apply for an upgrade to a Class A license if they meet certain criteria, including operating in a Designated Market Area (DMA) with not more than 95,000 television households. The FCC's order adopted this limitation and used Nielsen’s Local TV Report to determine a station’s DMA.RCC operates an LPTV station, W24EZ-D, in Connecticut, which is licensed to serve Allingtown, a neighborhood of West Haven with fewer than 15,000 television households. However, the station is part of the Hartford-New Haven DMA, which has approximately one million television households. RCC challenged the FCC's order, arguing that the size limitation should apply to a station’s community of license, not its DMA. RCC also raised other statutory and constitutional arguments, including claims that the order contravenes section 307(b) of the Communications Act, violates the Commerce Clause, improperly delegates legislative authority to Nielsen, and restricts programming content in violation of the First Amendment.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the FCC's order adheres to the best reading of the LPPA, which clearly limits Class A license eligibility to LPTV stations operating in a DMA with not more than 95,000 television households. The court found that the FCC properly defined DMA according to Nielsen’s data, as authorized by Congress, and that the statute does not reference "community of license." The court also rejected RCC's constitutional arguments, finding that the FCC's interpretation did not violate the Commerce Clause or the nondelegation doctrine. Consequently, the court denied RCC's petition for review. View "Radio Communications Corporation v. FCC" on Justia Law

The case involves two organizations, Doc Society and International Documentary Association (IDA), which promote documentary filmmaking globally. They challenged a policy by the Secretary of State requiring visa applicants to disclose their social media information from the past five years. The plaintiffs argued that this policy violated the First Amendment and the Administrative Procedure Act, claiming it impeded their core activities and harmed their members.The United States District Court for the District of Columbia found that the plaintiffs had organizational standing but dismissed their claims on the merits, stating they failed to state a claim under the First Amendment or the Administrative Procedure Act. The district court dismissed the complaint with prejudice.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court concluded that the plaintiffs did not adequately allege that a favorable decision would redress their claimed injuries. The court found that the plaintiffs lacked standing because they did not provide specific allegations showing that their partners and members would return to their prior use of social media or reconsider their willingness to travel to the United States if the policy were vacated. The court reversed the district court's determination that the plaintiffs had standing, vacated the remainder of the district court's order, and remanded the case for further proceedings, including whether the plaintiffs should be granted leave to amend their complaint. View "Doc Society v. Rubio" on Justia Law

N.S. was arrested for robbery and destruction of property and was released on his own recognizance by a Magistrate Judge. However, before he could leave the courthouse, U.S. Marshals detained him based on an ICE detainer. N.S. filed a class complaint alleging that the Marshals acted beyond their statutory authority by making a civil immigration arrest, violating the Administrative Procedure Act.The United States District Court for the District of Columbia certified the proposed class and granted N.S.'s request for a permanent injunction, prohibiting Marshal Dixon and his agents from arresting and detaining criminal defendants in the Superior Court for suspected civil immigration violations. The court held that the Marshals were not authorized to make civil immigration arrests as they had not undergone the required training. The court also found that the 2002 Order delegating authority to the Marshals lacked sufficient legal support.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Marshals were not authorized to make civil immigration arrests due to the lack of required training. However, the court found that the class-wide injunction issued by the district court was barred by 8 U.S.C. § 1252(f)(1), which prohibits lower courts from enjoining the operation of certain immigration provisions. The court vacated the injunction and remanded the case to the district court to reconsider the appropriate remedy. View "N.S. v. Dixon" on Justia Law

Brenda Zaragoza fell in the parking lot of a Johnson County public library, resulting in serious injuries. She sued the Johnson County Board of Commissioners, alleging negligence for failing to mitigate the presence of a storm drain and warn of the change in elevation between the curb and the parking surface. The district court granted summary judgment for the County, citing recreational use immunity under the Kansas Tort Claims Act (KTCA), which bars negligence claims arising from the use of public property intended for recreational purposes unless gross and wanton negligence is involved. The court also denied Zaragoza's motion to amend her petition to add a claim of gross and wanton negligence.The Kansas Court of Appeals affirmed the district court's decision, holding that the library's recreational use immunity applied and that the district court did not abuse its discretion in denying Zaragoza's untimely motion to amend her petition. Zaragoza then petitioned for review, raising both issues. After the petition was granted, she filed a supplemental brief raising a new constitutional argument, which was not considered because it was not presented in her petition for review or before the lower courts.The Kansas Supreme Court upheld the lower courts' decisions. The court declined to consider Zaragoza's unpreserved constitutional challenge. It affirmed the district court's grant of summary judgment, agreeing that the library's parking lot fell under the recreational use immunity provision of the KTCA. The court also affirmed the district court's denial of Zaragoza's motion to amend her petition, finding no evidence of gross and wanton negligence by the County. The court concluded that the library is public property intended for recreational purposes and that the parking lot is integral to its function, thus qualifying for immunity under the KTCA. View "Zaragoza v. Board of Johnson County Comm'rs " on Justia Law

Plaintiffs, owners of a dairy farm and residences adjacent to Burlington International Airport, sued the City of Burlington for soil and water contamination caused by runoff from the airport. The contamination was due to the use of aqueous film-forming foam containing PFAS by the Vermont Air National Guard, which leased part of the airport. Plaintiffs alleged negligence, trespass, private nuisance, de facto taking, violation of the Vermont Groundwater Protection Act, increased water surface drainage, and direct negligence.The Superior Court, Chittenden Unit, Civil Division, dismissed the complaint for failure to join the United States and the Guard as necessary and indispensable parties, and on the basis of municipal immunity. The court found that the United States and the Guard were necessary parties because their actions were central to the claims and their absence could lead to inconsistent obligations for the City. The court also held that municipal immunity applied to the claims related to firefighting services.The Vermont Supreme Court reviewed the case. It affirmed the dismissal of the negligence claim (Count 1) because it was based on the Guard’s firefighting activities, making the United States and the Guard necessary parties. However, the court reversed the dismissal of the other claims (Counts 2-5 and 7), which were based on the City’s failure to contain contaminated water on its property. The court found that these claims did not require the presence of the United States or the Guard as necessary parties.The court also remanded the case for further consideration of whether municipal immunity applied to the City’s maintenance and operation activities alleged in the surviving counts. The court noted that municipal airport operations are generally considered proprietary functions, which are not protected by municipal immunity. The case was sent back to the lower court for further proceedings consistent with this opinion. View "Belter v. City of Burlington" on Justia Law

American Oversight, a nonprofit group, filed a petition for a writ of mandamus in district court against the Governor and the Attorney General of Texas, alleging violations of the Public Information Act (PIA). They sought official communications and other documents, which the Governor's and Attorney General's offices partially withheld, citing various exemptions. Dissatisfied with the responses, American Oversight pursued legal action to compel the release of the information.The Travis County district court denied the State's pleas to the jurisdiction, leading to an interlocutory appeal. The State argued that the district court lacked jurisdiction to issue a writ of mandamus against constitutional executive officers, as only the Texas Supreme Court has such authority under section 22.002(c) of the Texas Government Code. The court of appeals affirmed the district court's decision, holding that section 552.321(b) of the PIA authorized district courts to issue mandamus relief against any governmental body, including those headed by constitutional executive officers.The Supreme Court of Texas reviewed the case and concluded that section 552.321(b) did not expand the jurisdiction of district courts to issue writs of mandamus against constitutional executive officers. The Court held that only the Texas Supreme Court has the authority to issue such writs against these officers, as per section 22.002(c) of the Texas Government Code. Consequently, the Supreme Court of Texas reversed the judgment of the court of appeals and directed the district court to dismiss the mandamus petition for lack of jurisdiction. View "PAXTON v. AMERICAN OVERSIGHT" on Justia Law

Eugene Sikora, a former prisoner, claims that the State of Iowa failed to release him from prison when his sentence was over. He was convicted of three felonies in 2016 and sentenced to concurrent five-year terms, which were suspended for probation. In 2017, his probation was revoked, and he was imprisoned until March 2019. Sikora alleges that due to a miscalculation, he was imprisoned for nearly five months longer than allowed, as the defendants did not credit him for 292 days served in county jails and a custodial residential center.Sikora filed a suit over three years after his release, seeking money damages for wrongful imprisonment. He named the State of Iowa and the director of the Iowa Department of Corrections as defendants, asserting five tort claims, including violations of his constitutional rights and negligence. The defendants moved to dismiss the suit, arguing sovereign immunity and other defenses. The district court dismissed some of Sikora’s claims but allowed others to proceed. However, after the Iowa Supreme Court's decision in Burnett v. Smith, which overruled the precedent allowing constitutional tort claims, the district court dismissed Sikora’s remaining claims and denied his motion to amend his petition to add new defendants and claims.The Iowa Supreme Court affirmed the district court’s dismissal, holding that sovereign immunity barred Sikora’s claims. The court concluded that all of Sikora’s claims were essentially false imprisonment claims, which are barred by sovereign immunity under Iowa Code section 669.14(4). The court also rejected Sikora’s arguments that constitutional torts and claims against individual state employees could proceed, emphasizing that the Iowa Tort Claims Act (ITCA) provides the exclusive mechanism for such claims and explicitly prohibits claims based on false imprisonment. View "Sikora v. State of Iowa" on Justia Law

Annette R. Deal served in the U.S. Navy and Army and filed a claim for compensation for Cushing’s syndrome and a nervous condition in 1991, which was denied in 1992. She received treatment within the appeal period, resulting in a 1993 medical record being added to her file. The VA did not address whether this record met the requirements to be considered new and material evidence until 2021. Mrs. Deal did not appeal the 1992 decision. She filed another claim in 1995, which was partially granted, and a third claim in 2003, leading to a 2016 decision granting service connection for her psychiatric disorder with an effective date of August 1, 2003.The Board of Veterans’ Appeals granted an effective date of March 10, 1995, for her psychiatric disorder, ruling that new and material evidence was presented in 1997. However, it denied an effective date of October 1991, ruling that the 1993 record was not material. Mrs. Deal appealed to the United States Court of Appeals for Veterans Claims, which affirmed the Board’s decision, finding a plausible basis for ruling that the 1993 record was not material.The United States Court of Appeals for the Federal Circuit reviewed the case. Mrs. Deal argued that the VA’s failure to address the 1993 record before the 2016 decision meant her 1991 claim remained open, entitling her to an earlier effective date. The court disagreed, stating that the VA’s delay does not automatically entitle a claimant to an earlier effective date unless the evidence is determined to be new and material. The court affirmed the Veterans Court’s decision, holding that the 1993 record was not material and the 1992 decision was final. View "Deal v. Collins" on Justia Law