Justia Government & Administrative Law Opinion Summaries

This case involves a dispute between the International Association of Firefighters, Local 1319, AFL-CIO (Local 1319) and the City of Palo Alto (the city). In 2011, the city, facing a budget crisis, proposed an amendment to its city charter to alter a provision requiring certain labor disputes with its public safety unions to be submitted to binding interest arbitration. The city council adopted a resolution proposing the amendment, which was subsequently approved by city voters as "Measure D". However, the city did not consult with Local 1319 before proposing the amendment, which both the Public Employment Relations Board (PERB) and the appellate court later determined was a violation of the Meyers-Milias-Brown Act (MMBA).The trial court in the quo warranto proceedings agreed that the city violated the MMBA by enacting the resolution and submitting Measure D to the voters without prior good faith consultation with Local 1319. However, the trial court did not declare Measure D invalid. Instead, it issued a multi-step order that suspended the operation of the charter’s current dispute resolution procedures, required good faith consultation between the city and the public safety unions, and retained jurisdiction with the possibility of a future finding of invalidity of Measure D.The Court of Appeal of the State of California, Sixth Appellate District, reversed the trial court's judgment. The appellate court held that the trial court abused its discretion by not invalidating Measure D after finding that the city's submission of Measure D to the voters violated the MMBA. The appellate court directed the trial court on remand to enter a new judgment ordering the city to restore the pre-amendment portion of the city charter's article V, invalidating Measure D, and providing any other appropriate relief consistent with the appellate court's opinion. View "P. ex rel. Internat. Assn. of Firefighters v. City of Palo Alto" on Justia Law

The case involves a dispute between investigative journalist Amy Silverman and the Arizona Department of Economic Security (ADES). Silverman requested access to records maintained by the Adult Protective Services (APS), a program within ADES, for her research on issues affecting individuals with intellectual and developmental disabilities. ADES denied her request, citing a state law that generally shields APS records from public inspection, except for certain exceptions, including one for "bona fide research." Silverman sued ADES, arguing that her journalistic activities qualified as "bona fide research."The Superior Court in Maricopa County ruled in favor of Silverman, finding that her journalistic activities qualified as "bona fide research" and ordered ADES to produce the requested documents after redacting personally identifying information. ADES appealed this decision, and the Court of Appeals affirmed in part, reversed in part, and remanded the case back to the Superior Court. The Court of Appeals concluded that "research" under the exception must be conducted for "educational, administrative, or scientific purposes" and that ADES still has discretion whether to disclose APS records.Both parties were dissatisfied with the Court of Appeals' decision and filed petitions for review with the Supreme Court of the State of Arizona. The Supreme Court concluded that "bona fide research" under the relevant statute occurs when the researcher engages in a good faith and genuine study to acquire more knowledge, discover new facts, or test new ideas concerning reporting or stopping the abuse, exploitation, or neglect of vulnerable adults. The court also held that anyone, including journalists, can qualify under the bona fide research exception. However, the court found that ADES has discretion whether, and on what conditions, to release APS records for bona fide research. The court vacated the Court of Appeals' opinion, affirmed the Superior Court's judgment insofar as it denied ADES's motion to dismiss, but reversed the judgment for Silverman and remanded the case for further proceedings. View "SILVERMAN v ADES" on Justia Law

The case revolves around Elizabeth Carley, an inmate in the custody of the Nevada Department of Corrections (NDOC), who filed a suit against Dr. Romeo Aranas, the former Medical Director of NDOC. Carley alleged that Dr. Aranas was deliberately indifferent to her medical needs when he denied her request for certain Hepatitis C (HCV) treatment. The district court denied Dr. Aranas' motion for summary judgment, concluding that he was not entitled to qualified immunity at that time.Previously, the district court had concluded that there was a genuine dispute of material fact as to whether Dr. Aranas was deliberately indifferent to Carley's serious medical needs. However, it did not proceed to the second step of the qualified immunity inquiry, which was whether the violation was clearly established at the time of the violation.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Dr. Aranas was entitled to qualified immunity because no clearly established law rendered the HCV policies unconstitutional at the time of the alleged violation. The court concluded that no decision of the Supreme Court, this court, or a “consensus of courts” would have put Dr. Aranas on notice that the relevant inmate treatment prioritization schemes violated the Eighth Amendment during his time as the NDOC Medical Director. Therefore, the court reversed the district court’s order and remanded with instructions to grant summary judgment for Dr. Aranas. View "CARLEY V. ARANAS" on Justia Law

The case involves Gerardo Farias-Contreras, who pleaded guilty to conspiring to distribute methamphetamine and heroin. As part of the plea agreement, the government agreed to dismiss two other charges and not to recommend a sentence exceeding the low-end of the guideline range. Farias-Contreras argued for a six-level reduction in the base offense level, resulting in a guidelines range of 108–135 months, citing his many physical disabilities. The government, after reducing the base offense level by three levels, calculated a guidelines range of 151–188 months and recommended a 151-month term.The United States District Court for the Eastern District of Washington sentenced Farias-Contreras to 188 months' imprisonment, citing substantially the facts and argument presented by the government. Farias-Contreras appealed, arguing that the government implicitly breached its promise under the plea agreement not to recommend a sentence in excess of the low-end of the sentencing guidelines range when the government implicitly urged the district court to impose a harsher sentence.The United States Court of Appeals for the Ninth Circuit affirmed the sentence. The court found that the government's conduct crossed the line from permissible advocacy to an improper end-run of the plea agreement, thus implicitly breaching its promise not to recommend a sentence in excess of the low-end of the calculated guideline range. However, the court concluded that the error was not plain because the court's precedent does not make sufficiently clear to what extent the government may respond to a defendant’s request for a downward departure without implicitly breaching the plea agreement. The court took the opportunity to clarify its law on the subject. View "USA V. FARIAS-CONTRERAS" on Justia Law

The Supreme Court of New Mexico affirmed the decision of the New Mexico Public Regulation Commission (PRC) to deny Southwestern Public Service Company’s (SPS) application for a financial incentive under the Renewable Energy Act (REA). SPS had proposed to retire renewable energy certificates (RECs) earlier than required to exceed the Renewable Portfolio Standard (RPS), and in return, requested a rate rider that would allow it to charge customers one dollar for each REC retired over the twenty percent standard. The PRC denied the application, finding that SPS’s proposal did not meet the REA’s requirement to “produce or acquire renewable energy” to qualify for an incentive. The court agreed with the PRC’s interpretation of the REA, stating that the act of retiring RECs alone does nothing to further the statute’s objectives. The court also rejected SPS’s challenges to the PRC’s amendments to Rule 572, which governs the award of incentives under the REA. The court found that the amendments did not exceed the scope of the REA, were not arbitrary or capricious, and were not otherwise unreasonable or unlawful. View "S.W. Pub. Serv. Co. v. N.M. Pub. Regul. Comm'n" on Justia Law

A Rhode Island oral and maxillofacial surgeon, Dr. Stephen T. Skoly, refused to comply with a COVID-19 Emergency Regulation issued by the Rhode Island Department of Health (RI DOH) that required all healthcare workers and providers to be vaccinated against COVID-19. Following his public declaration of noncompliance, the RI DOH issued a Notice of Violation and Compliance Order against him. Skoly then filed a lawsuit in federal court against the state and its officials, alleging violations of equal protection, due process, and First Amendment rights. The district court dismissed his complaint under Federal Rule of Civil Procedure 12(b)(6).The district court's decision was based on the fact that the state officials were either entitled to absolute or qualified immunity for their actions. The court held that the RI DOH directors were exercising prosecutorial authority delegated to them by Rhode Island law, thus granting them absolute immunity. As for Governor McKee, the court found that he was protected by qualified immunity as Skoly had no clearly established right to continue practicing while violating the vaccine mandate. The court also rejected Skoly's First Amendment retaliation claim, stating that the posting of the Notice constituted government speech, which could not form the basis of a plausible First Amendment retaliation claim.Upon appeal, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Skoly's complaint. The appellate court agreed with the lower court's findings that the state officials were entitled to either absolute or qualified immunity and that Skoly's constitutional claims were without merit. The court also upheld the dismissal of Skoly's First Amendment retaliation claim, stating that Skoly had not sufficiently alleged that he was targeted due to his opposition to the First Emergency Regulation. View "Skoly v. McKee" on Justia Law

The case revolves around Morgan Morales, who appealed against an administrative law judge's (ALJ) decision that she was not disabled and hence, not entitled to Social Security disability benefits. Morales claimed to suffer from several conditions, including bipolar disorder, depression, anxiety, ADHD, and narcolepsy. After being treated at a mental health center and starting on prescription medications, Morales reported that her conditions were in remission. The ALJ, however, denied her application for benefits, finding that her mental impairments were mild and did not limit her ability to perform basic work activities, including her past job as a material handler.Morales challenged the ALJ's decision in the United States District Court for the Southern District of Indiana, Indianapolis Division. She criticized the ALJ's decision about her functional capacity to work but failed to provide evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The District Court upheld the ALJ's decision, stating that Morales had not carried her burden of proof and that the ALJ's decision was supported by substantial evidence.The case was then brought to the United States Court of Appeals for the Seventh Circuit. The court affirmed the lower court's decision, stating that Morales had misunderstood the burden she bore on appeal. The court noted that it was not enough to criticize the ALJ's decision; Morales needed to point to evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The court also dismissed Morales's criticism of the District Court's decision, stating that the District Court had conducted an adequate review of the ALJ's determination and correctly applied the law. The court concluded that the ALJ's determination was reasonable and supported by substantial evidence, and therefore, affirmed the decision. View "Morales v. O'Malley" on Justia Law

The case involves Absolute Healthcare, operating as Curaleaf, a company that runs medical marijuana dispensaries across the United States. The National Labor Relations Board (NLRB) found that Curaleaf committed four unfair labor practices, including unlawfully firing an employee, Anissa Keane, for attempting to unionize a Curaleaf store in Gilbert, Arizona. The NLRB also ordered Curaleaf to read aloud to its Gilbert-based employees a notice describing the Board’s findings and to grant the union access to Curaleaf’s Gilbert store.The case was initially heard by an administrative law judge who found in favor of the NLRB on all four charges. The judge ordered Curaleaf to reinstate Keane with backpay, to read aloud a notice of the unfair labor practice findings to Curaleaf Gilbert employees, and to grant the union access to Curaleaf Gilbert’s facilities any time Curaleaf spoke to its employees about unionization. Curaleaf appealed to the NLRB, challenging only the unlawful-discharge finding and the notice-reading and union-access remedies. A divided three-member panel of the NLRB affirmed the administrative law judge's decision.The case was then reviewed by the United States Court of Appeals for the District of Columbia Circuit. The court held that the NLRB's finding that Curaleaf unlawfully fired Keane was not supported by substantial evidence. The court also held that the NLRB's notice-reading and union-access remedies could not be enforced. However, the court granted the NLRB's cross-application for enforcement as to the three uncontested unfair labor practices. View "Absolute Healthcare v. National Labor Relations Board" on Justia Law

The case involves Marcus Womack, who was arrested in 2017 following a search warrant executed at a residence in Huntingdon County, Pennsylvania. The search revealed that Womack had been selling drugs from the location, and he was found in possession of a large sum of money, drugs, and a stolen firearm. On the same day, a criminal complaint was filed against Womack, charging him with nine offenses. Unable to post bail, Womack remained in custody. Subsequent investigations revealed that Womack's drug enterprise extended beyond Huntingdon County, leading to the involvement of the Office of the Attorney General (OAG) and a statewide investigating grand jury. In 2018, a second criminal complaint was filed against Womack, charging him with twenty-eight offenses based on evidence gathered during the grand jury investigation.The trial court denied Womack's motion to dismiss the second complaint under Pa.R.Crim.P. 600(D)(1), which requires a trial to commence within 365 days from the date the complaint is filed. Womack's motion to dismiss the first complaint on the same grounds was granted. Womack was found guilty of several offenses in a bench trial on the second complaint and was sentenced to an aggregate term of 39 to 90 years’ imprisonment. He appealed to the Superior Court, arguing that the computation of time for Rule 600 purposes should have been based on the filing date of the first complaint. The Superior Court affirmed the trial court's decision.The Supreme Court of Pennsylvania affirmed the Superior Court’s order denying relief. The court applied the test from Commonwealth v. Meadius, which requires the Commonwealth to demonstrate due diligence between the period in which the complaints were filed, establish that the filing of the second complaint was necessitated by factors beyond its control, and show that its actions were not an attempt to circumvent or manipulate the speedy trial requirements. The court found that the Commonwealth met these requirements, and therefore, the Rule 600 clock began when the second complaint was filed. View "Commonwealth v. Womack" on Justia Law

In January 2020, Tiffany McClure, a probation officer, responded to a call for assistance during riots at the state penitentiary at Parchman. She alleges that the Mississippi Department of Corrections (MDOC) failed to pay her the promised overtime wages. This case is part of a series of actions filed by probation and parole officers seeking unpaid wages for their overtime work with the MDOC. The main question is whether Mississippi courts have jurisdiction to hear state employees’ claims against their employers for breach of contract.The MDOC argued that the Hinds County County Court erred by not dismissing McClure’s claims due to lack of subject matter jurisdiction. They contended that employment-related grievances are exclusively reviewed by the Employee Appeals Board, and any non-grievable claims have no right to relief under state law. McClure agreed that her claims were non-grievable, but asserted that the Hinds County County Court was the only forum that could provide relief.The Supreme Court of Mississippi affirmed the trial court’s ruling, stating that the Mississippi Constitution vests original jurisdiction with the circuit courts, and there are no adequate administrative remedies for McClure’s breach of contract and constitutional claims. However, the court noted that its holding was narrowly tailored to the specific facts of this case. The court also affirmed the Hinds County County Court's exercise of jurisdiction over the matter and remanded the case for further proceedings. View "Mississippi Department of Corrections v. McClure" on Justia Law