Justia Government & Administrative Law Opinion Summaries

The case involves the death of Andrew Dawson Bell, who committed suicide while detained at the Washington County Detention Center (WCDC) in Fayetteville, Arkansas. Bell's mother, Judy Lynn Smith-Dandridge, filed a lawsuit against several Fayetteville Police Department officers, WCDC employees, nurses, and Washington County itself, alleging that they were deliberately indifferent to Bell's serious medical needs, in violation of 42 U.S.C. § 1983 and the Arkansas Civil Rights Act, Arkansas Code Ann. § 16-123-105. The district court granted summary judgment in favor of all defendants, and Smith-Dandridge appealed to the United States Court of Appeals for the Eighth Circuit.Bell had a history of mental illness and substance abuse. On the day he died, Bell had called the police several times, reporting hallucinations of people trying to break into his apartment. Officers responded but found no evidence of a break-in. They arrested Bell for terroristic threats, disorderly conduct, and carrying a weapon. When Bell was processed into WCDC, he informed the intake officers of his mental health history, including a history of suicidal ideation. Despite this, he was placed in the general population.The main issue on appeal was whether the police officers and WCDC personnel had knowledge of Bell's substantial risk of suicide and deliberately disregarded it. Smith-Dandridge argued that the officers’ interactions with Bell and their review of his arrest history established they had the requisite knowledge to establish deliberate indifference. However, the court found that while Bell's behavior put the officers on notice of signs of mental illness, it did not make it obvious to them that Bell had a substantial risk of suicide. Similarly, the court found that the WCDC personnel's inaction to prevent Bell's suicide did not constitute criminal recklessness.The court also dismissed Smith-Dandridge's claim that Washington County was deliberately indifferent in its failure to train jail staff. The court found that Smith-Dandridge failed to show that the alleged deficient training caused WCDC personnel to be deliberately indifferent to Bell's substantial risk of suicide. As such, the court affirmed the district court's grant of summary judgment in favor of all defendants. View "Smith-Dandridge v. Geanolous" on Justia Law

The case involves two separate petitions for review of decisions made by the Federal Energy Regulatory Commission (FERC) to grant extensions of time for the completion of natural gas pipeline projects. The petitioners are Sierra Club and Public Citizen, and the respondents are FERC and the project developers, National Fuel Gas Supply Corporation, Empire Pipeline Inc., Cheniere Corpus Christi Pipeline L.P, and Corpus Christi Liquefaction LLC.The petitions primarily contend that FERC was overly generous in finding "good cause" to grant extensions for the completion of the pipeline projects. The petitioners argue that due to changes in circumstances, such as the introduction of New York's 2019 Climate Act, FERC was obliged to reconsider its original findings of market need for the projects.The court upheld FERC's decisions, finding that it exercised its broad discretion reasonably in both cases. It concluded that FERC's determinations of "good cause" were supported by the record, including National Fuel's litigation over water-quality certification and Cheniere's disrupted investment decision due to the COVID-19 pandemic. The court also found that FERC appropriately decided not to reevaluate its prior findings of market need for the pipeline projects. The court ruled that the petitioners' proposed stricter approach to assessing extension requests was unsupported by the Natural Gas Act and the Administrative Procedure Act. Therefore, the petitions for review were denied. View "Sierra Club v. FERC" on Justia Law

A medical malpractice lawsuit was filed by Dwan and Aaron Bray, individually and on behalf of their minor child, against Dr. Timothy J. Thress and various other medical entities. The suit, which was initially filed in state court, related to alleged negligence in Dwan Bray's prenatal care and the subsequent birth of their child. However, Thress was employed by a federally funded health center during his treatment of Bray. Under the Federally Supported Health Centers Assistance Act (FSHCAA), the lawsuit was removed to federal court and the United States was substituted as the defendant.The U.S. government moved to dismiss the case, arguing that the plaintiffs failed to satisfy the Federal Tort Claims Act’s (FTCA) administrative exhaustion requirement. The plaintiffs countered by moving to remand the action to state court, arguing that the FSHCAA did not apply. The district court denied both of plaintiffs’ motions, finding the FSHCAA applicable and any attempt to amend plaintiffs’ complaint futile. The district court dismissed plaintiffs’ FTCA claim without prejudice and remanded plaintiffs’ claims against the remaining defendants to state court. The plaintiffs appealed the district court’s denial of their motion to remand and its dismissal of their FTCA claim.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decisions. It held that Thress's conduct was covered by the FSHCAA, and that the plaintiffs' attempts to amend their complaint were futile since they had failed to exhaust their administrative remedies under the FTCA before instituting the lawsuit. View "Bray v. Bon Secours Mercy Health, Inc." on Justia Law

The Supreme Court of Mississippi was asked to decide whether the Mississippi State Department of Health (MSDH) was required to admit evidence of a concurrent Certificate of Need (CON) application during the CON hearing for another healthcare facility. The MSDH had simultaneously considered two CON applications, one from Encompass Health Rehabilitation Hospital and one from Baptist Memorial Rehabilitation Hospital, for the same category of services. The MSDH did not admit the Baptist application or certificate, and the chancery court reversed the decision solely on this issue.The Supreme Court of Mississippi ruled that the chancery court was in error, and that the MSDH's decision on relevance or its decision not to reopen a closed hearing was not reversible error. The Supreme Court found that the MSDH did not abuse its discretion or violate due process in determining that the Baptist CON application was not relevant to the Encompass' CON application proceedings.The Supreme Court vacated the chancery court’s decision and remanded the case to the chancery court for a decision on the merits of Methodist’s appeal. The chancery court had failed to address the substance of Methodist’s appeal regarding the granting of a CON to Encompass, and the issue was not squarely before the Supreme Court. View "Encompass Health Rehabilitation Hospital of Flowood, LLC v. Mississippi Methodist Hospital and Rehabilitation Center, Inc." on Justia Law

In this case, a group of electricity providers challenged orders by the Federal Energy Regulatory Commission (FERC), arguing that FERC allowed a new auction rule to apply retroactively to a pending auction. The auction was overseen by PJM Interconnection L.L.C., a FERC-regulated wholesale market operator. PJM had halted the auction upon realizing that the results could lead to a high clearing price for a particular region due to a faulty assumption regarding the participation of certain resources. PJM sought and received permission from FERC to amend the tariff to allow it to adjust the Locational Deliverability Area (LDA) Reliability Requirement downward, reflecting the lack of participation of certain resources.The petitioners argued that this violated the filed rate doctrine, which prohibits retroactive rates. The court agreed, finding that the tariff amendment was retroactive because it altered the legal consequence attached to a past action: it allowed for the use of a different LDA Reliability Requirement than the one PJM had calculated and posted. The court noted that equitable considerations did not factor into the application of the filed rate doctrine, emphasizing the importance of predictability in the electricity markets.The court granted the petitions and vacated the orders in relevant part, specifically the portion of FERC’s orders that permitted PJM to apply the tariff amendment to the 2024/25 capacity auction. View "Constellation Energy Generation LLC v. FERC" on Justia Law

Several power providers and their associations challenged orders from the Federal Energy Regulatory Commission (FERC) that retroactively permitted a new auction rule to apply to a pending auction. The rule was implemented by PJM Interconnection L.L.C., the entity responsible for the auction, to determine the auction's results. The petitioners claimed FERC's orders violated the filed rate doctrine, which prohibits retroactive rates. The case background involves the Federal Power Act (FPA), which grants FERC exclusive jurisdiction over rates for the transmission and wholesale of electric energy in interstate commerce. The FPA requires all related rates, rules, and regulations to be "just and reasonable" and not unduly preferential.The petitioners and FERC agreed that the filed rate was the PJM Open Access Transmission Tariff, which sets the procedures governing PJM’s capacity auctions. PJM administered a capacity auction in December 2022 for capacity in the June 2024 – May 2025 period. A dispute arose when PJM sought to adjust the Locational Deliverability Area (LDA) Reliability Requirement due to perceived anomalies in the auction results, which would have resulted in a high clearing price for a certain region. FERC approved the proposed adjustment, which was challenged by the petitioners.The court agreed with the petitioners and held that the orders of FERC were retroactive and thus violated the filed rate doctrine. The court granted the petitions and vacated the orders in the relevant part. The court emphasized that the equities play no role in the application of the filed rate doctrine and that predictability is of paramount importance in electricity markets. It concluded that FERC’s disregard of the filed rate doctrine creates unpredictability in the markets and may ultimately harm consumers who buy electricity in those markets. View "Electric Power Supply Association v. FERC" on Justia Law

A group of power providers contested orders from the Federal Energy Regulatory Commission (FERC) that permitted a new auction rule to retroactively apply to a pending auction. The petitioners argued that this violated the filed rate doctrine, which forbids retroactive rates. The auction, administered by the PJM Interconnection LLC (PJM), aimed to ensure reliable electric supply at competitive prices. PJM halted the auction, seeking FERC's permission to amend certain auction parameters it had already posted, which, if left uncorrected, might have led to a high clearing price for a specific region. FERC approved the amendment and allowed it to apply to the halted auction, which the petitioners challenged. The United States Court of Appeals for the Third Circuit agreed with the petitioners, stating that the amendment was retroactive as it altered the legal consequence attached to PJM's past action in the auction. The court granted the petitions and vacated the portion of FERC's orders that allowed the amendment to apply to the auction in question. View "NRG Power Marketing v. FERC" on Justia Law

The case involves a dispute over the Federal Energy Regulatory Commission (FERC) allowing a new auction rule to apply retroactively to a pending auction. This auction was administered by PJM Interconnection L.L.C., an entity responsible for running the auction. The petitioners, electric suppliers and their trade associations, contended that FERC's orders violated the filed rate doctrine, which forbids retroactive rates.The United States Court of Appeals for the Third Circuit found that the Tariff Amendment was retroactive because it altered the legal consequence attached to a past action when it allowed PJM to use a different Locational Deliverability Area (LDA) Reliability Requirement than the one it had calculated and posted. The court noted that the Tariff Amendment, therefore, violated the filed rate doctrine.The court ruled that the doctrine's predictability is crucial because electricity markets depend on it. FERC’s disregard of the filed rate doctrine created unpredictability in the markets, potentially eroding confidence in the markets and ultimately harming consumers who buy electricity in those markets.The court granted the petitions for review and vacated the portion of FERC’s orders that allowed PJM to apply the Tariff Amendment to the 2024/25 capacity auction. View "Constellation Energy Generation LLC v. FERC" on Justia Law

This case involved several petitioners challenging orders of the Federal Energy Regulatory Commission (FERC), which allowed a new auction rule to retroactively apply to an auction that was already underway. The auction was managed by PJM Interconnection L.L.C. (PJM), which ran the auction based on a tariff (filed rate) that set out specific procedures. The petitioners argued that FERC's orders violated the filed rate doctrine, which prohibits retroactive rates.The United States Court of Appeals for the Third Circuit agreed with the petitioners. The court found that the new rule was retroactive because it altered the legal consequences attached to past actions. Specifically, the rule allowed PJM to use a different Locational Deliverability Area (LDA) Reliability Requirement than the one it had calculated and posted.The court noted that, while FERC's orders were seemingly intended to prevent potential economic harm to consumers, the filed rate doctrine's emphasis on predictability and the necessity of adherence to approved rates were paramount. The court concluded that FERC's orders, by allowing a change to the rules of an auction already in progress, introduced unpredictability into the electricity market, potentially eroding market confidence.Therefore, the court granted the petitions for review and vacated the portion of FERC's orders that allowed PJM to apply the new rule to the auction that was already underway. The court did not strike down the rule entirely, leaving open the possibility of it being applied to future auctions. View "Electric Power Supply Association v. FERC" on Justia Law

In this case, a group of electricity suppliers and their trade associations challenged orders of the Federal Energy Regulatory Commission (FERC) that permitted PJM Interconnection L.L.C., a wholesale market operator, to apply a new auction rule retroactively to a pending auction. The petitioners argued that FERC's orders violated the filed rate doctrine, which prohibits retroactive rates. The United States Court of Appeals for the Third Circuit agreed and granted the petitions, vacating the relevant parts of the orders.The central issue revolved around the Locational Deliverability Area (LDA) Reliability Requirement, a key parameter in PJM's auction process. Prior to the auction, PJM had miscalculated the LDA Reliability Requirement, which led to a potential price increase for a specific region. To correct this, PJM sought FERC's permission to amend the tariff to allow for a downward adjustment of the LDA Reliability Requirement. FERC granted this permission, allowing the new rule to apply to the ongoing auction, which the petitioners argued was a retroactive change in violation of the filed rate doctrine.The court found that the tariff amendment was indeed retroactive as it altered the legal consequence attached to a past action, specifically, PJM's calculation and posting of the LDA Reliability Requirement. The court held that the filed rate doctrine did not yield to equities and that the tariff amendment's retroactivity created instability in the electricity market. Consequently, the court vacated the portion of FERC's orders that allowed PJM to apply the tariff amendment to the 2024/25 capacity auction. View "NRG Business Marketing LLC v. FERC" on Justia Law