Justia Government & Administrative Law Opinion Summaries

A consumer, Reginald Kirtz, secured a loan from the Rural Housing Service, part of the U.S. Department of Agriculture. Although Kirtz repaid his loan by mid-2018, the USDA continued to tell credit report company TransUnion that his account was past due, harming his credit score. The USDA failed to correct its records after being notified of the error, and Kirtz sued the agency under the Fair Credit Reporting Act.The USDA argued that the case should be dismissed based on sovereign immunity, since the Supreme Court has held that the federal government is immune from suits for damages unless Congress waives that immunity. The agency claimed that the FCRA does not make the federal government amenable to suit for a violation. The district court agreed, but the Third Circuit Court of Appeals reversed, finding that the FCRA authorizes suits for damages against any person who violates the Act, and “person” is defined to include any government agency.The U.S. Supreme Court affirmed the decision of the Third Circuit, finding that sovereign immunity did not bar Kirtz’s claim. The Court held that the federal government is susceptible to suit when it provides false information to credit reporting agencies. It noted that dismissing a suit like Kirtz’s case would effectively negate a claim that Congress has clearly authorized. The Court’s ruling resolved a circuit split between the Third, Seventh, and D.C. Circuits, with which the Court agreed, and the Fourth and Ninth Circuits, with which it disagreed. View "Department of Agriculture Rural Development Rural Housing Service v. Kirtz" on Justia Law

In the case before the Supreme Court of the State of South Dakota, petitioners Tammy Bohn, Justin Bohn, and Brenda Vasknetz (collectively, the Citizens) sought a writ of mandamus against several city officials after the finance officer for the City of Sturgis declined to certify their petition to hold an election to remove the position of city manager from the City’s government. The circuit court denied the writ by granting summary judgment in favor of the City. The Citizens appealed this decision.The Supreme Court of the State of South Dakota reversed the circuit court’s decision. The Court concluded that the finance officer had a clear duty under administrative rules to certify the petition and present it to the city council, as long as the petition was in the correct form, contained the necessary number of valid signatures, and met the requirements in terms of header and verification. The Court held that neither the finance officer nor the city council had the authority to delay the scheduling of an election to vote on the submitted petition. Their attempts to do so were based on their mistaken belief that the law does not allow citizens to request an election on whether the City should no longer utilize a city manager.As a result, the Court remanded the case to the circuit court to enter a writ of mandamus directing the city council to schedule and hold an election consistent with the relevant statute as presented in the petition. The Court also concluded that the Citizens were not entitled to attorney fees, but, as the prevailing party, they were entitled to costs. View "Bohn V. Bueno" on Justia Law

In 2006, Charles H. Lester, Jr. was sentenced to 188 months' imprisonment and 5 years of supervised release for conspiring to distribute methamphetamine. After serving a portion of his supervised release term, the United States Probation Office filed a report recommending the early termination of Lester's supervision, citing his low risk of recidivism and compliance with the conditions of his supervision. The United States District Court for the Eastern District of Missouri denied this request, asserting that it did not have the authority to terminate Lester's supervised release early due to the requirement in 21 U.S.C. § 841(b)(1)(A) that a five-year term of supervised release be imposed, which the court interpreted as precluding early termination under 18 U.S.C. § 3583(e)(1).Upon appeal, the United States Court of Appeals for the Eighth Circuit disagreed with the district court's interpretation. The appellate court held that the language of § 841(b)(1)(A) requires the imposition of a five-year term of supervised release, but does not impact a district court's ability to later terminate an individual's supervised release after the individual has served at least one year, as provided in § 3583(e)(1). Thus, the district court retained discretion to consider whether Lester's supervised release could be terminated early under § 3583(e)(1). Consequently, the appellate court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "United States v. Lester" on Justia Law

In the State of North Dakota, Dale Kringlie suffered a work-related injury to his right shoulder and wrist while using a concrete drill in April 2019. Workforce Safety and Insurance (WSI) accepted the claim and paid the associated medical expenses and disability benefits. WSI later issued a vocational rehabilitation plan for Kringlie, which he contested, asserting his inability to perform any of the jobs due to a neuropsychological condition. Kringlie sought the opinion of Dr. Swenson, who supported his claim. An Administrative Law Judge (ALJ) reversed WSI’s decision, basing his judgment heavily on Dr. Swenson's opinion. WSI appealed this decision to the district court, arguing that the ALJ erred by considering Kringlie’s functional limitations at the time of the vocational rehabilitation report issuance. The district court reversed the ALJ's decision, stating that WSI was only required to consider Kringlie's functional limitations at the time of his work-related injury. The Supreme Court of North Dakota affirmed the district court's decision, agreeing that the ALJ misapplied the law. The court held that the ALJ erred in considering Kringlie’s functional limitations at the time WSI issued the vocational rehabilitation report, rather than at the time of the work-related injury. Furthermore, the court ruled that the ALJ wrongfully relied on Dr. Swenson's opinion, which was not permitted under N.D.C.C. § 65-05-08.1. View "Workforce Safety and Insurance v. Kringlie" on Justia Law

In North Dakota, Friends of the Rail Bridge (FORB), Downtown Business Association of Bismarck (DBAB), and CD Holdings, LLC appealed from a judgment dismissing their administrative appeal due to lack of subject matter jurisdiction. The case arose when BNSF Railway Company applied for permits to construct a new rail bridge and remove the existing rail bridge across the Missouri River. FORB and DBAB requested the Department of Water Resources (DWR) to conduct a public hearing or meeting regarding the permits. After the permits were issued, FORB, DBAB, and CD Holdings appealed to the district court. The court dismissed the appeal, concluding they did not request a hearing under N.D.C.C. § 61-03-22, therefore it lacked subject matter jurisdiction.The Supreme Court of North Dakota, in an opinion written by Justice McEvers, affirmed the lower court's decision. The Supreme Court held that the appellants failed to perfect their appeal and the district court did not have subject matter jurisdiction over the appeal because the appellants did not request a hearing within 30 days after DWR’s issuance of the permits. Therefore, no hearing was held, nor was a hearing request denied by DWR. The court further clarified that the public meetings held were not hearings under N.D.C.C. § 61-03-22 and should not be confused with adjudicative proceedings. View "Friends of the Rail Bridge v. Dep't of Water Resources" on Justia Law

The plaintiff, Todd Hess, applied for supplemental security income, disability insurance benefits, and disabled adult child benefits, all of which are administered by the Social Security Administration. While his claims for supplemental security income and disability insurance benefits were approved, his claim for disabled adult child benefits was denied. To qualify for disabled adult child benefits, Hess had to prove that he had a disability that continued uninterrupted from before his 22nd birthday until the filing of his application for benefits. He claimed that his depression, panic disorder, obsessive-compulsive disorder, and other impairments made him disabled during that entire period. However, after two hearings, an Administrative Law Judge disagreed, concluding that Hess was disabled as of June 9, 2009, but not before then. The ALJ's decision was based on gaps in Hess's treatment history, notes from his physicians, and occasional work he performed as an independent contractor. The Appeals Council did not assume jurisdiction, and the district court found that the ALJ's decision was supported by substantial evidence. The United States Court of Appeals for the Seventh Circuit agreed and affirmed the judgment of the district court. View "Hess v. O'Malley" on Justia Law

The appellants, Google LLC and ecobee, Inc. had appealed from a decision of the United States Patent and Trademark Office’s Patent Trial and Appeal Board. The Board had found that the challenged claims of U.S. Patent No. 8,498,753, owned by EcoFactor, Inc., were not unpatentable. Google argued that the Board had made an erroneous claim construction of a limitation in Claim 1 and that Google had not been given notice or an opportunity to address the Board’s construction, thereby violating the Administrative Procedure Act. The United States Court of Appeals for the Federal Circuit held that the Board had indeed construed Claim 1 and that its construction was erroneous. The court vacated the Board’s decision and remanded the case for further proceedings under the correct construction of the [1m] limitation in Claim 1. View "GOOGLE LLC v. ECOFACTOR, INC. " on Justia Law

In South Carolina, the case revolves around the interpretation of a law concerning the calculation of the one-year maximum Community Supervision Program (CSP) revocation sentence. The key question is whether inmates arrested for alleged CSP violations should receive credit towards their potential CSP revocation sentence for the time they spent in jail awaiting the adjudication of the CSP violation charge. The Petitioner, Stacardo Grissett, violated the terms of his CSP and was denied credit for roughly six months he spent in jail awaiting his CSP revocation hearing. His appeal was dismissed as moot because he had completed his CSP revocation sentence and original sentence by the time it reached the Court of Appeals. The Supreme Court of South Carolina, however, chose to review the case due to its potential for repetition and the need for clarification. The court ruled that inmates must be given credit for any time served awaiting their CSP revocation hearing towards their CSP revocation sentence. The court's decision hinged on the interpretation of Section 24-21-560(C), which states that an inmate who is incarcerated for a CSP violation is not eligible to earn credits that would reduce the sentence. The court held that time served does not "reduce" a sentence, but only affects the date on which the sentence begins, thereby ruling in favor of the Petitioner. View "State v. Grissett" on Justia Law

A case in Connecticut involved a couple, Aaron Lynch and Jean-Marie Monroe-Lynch, who sought damages for alleged medical malpractice by the state of Connecticut in relation to therapeutic donor insemination (TDI) services and prenatal care provided at a state hospital. The couple were unable to conceive without medical assistance and pursued TDI services. The hospital staff failed to adhere to guidelines regarding the use of cytomegalovirus (CMV) positive donor sperm for CMV negative patients, leading to Jean-Marie being inseminated with CMV positive donor sperm. Jean-Marie later became pregnant with twins. During her pregnancy, an ultrasound revealed conditions associated with an in utero CMV infection, however, the hospital staff failed to inform Jean-Marie or take appropriate follow-up action. One of the twins died in utero from a severe CMV infection and the other was born with severe, lifelong medical conditions as a result of congenital CMV.The Supreme Court of Connecticut held that the state could not claim sovereign immunity as the plaintiffs' fertility treatment claims were medical malpractice claims, not informed consent claims. The court also held that the plaintiffs' son, who was born with severe medical conditions as a result of the state's negligence, was entitled to compensation. The court found no merit in the state's claim that the damages awarded were speculative or predicated on the concept that nonexistence can be preferable to impaired existence. The court concluded that common-law negligence principles were adaptable to provide a remedy for injuries such as those sustained by the plaintiffs' son. This decision affirms the trial court's award of over $34 million in damages to the plaintiffs. View "Lynch v. State" on Justia Law

This case involves a lawsuit against the United States for allegations of negligence in a search-and-rescue mission by the U.S. Coast Guard. The plaintiffs, the estate of Aaron Greenberg (who drowned in a boating accident), Adrian Avena (who survived the accident), and AA Commercial, LLC, claimed that the Coast Guard was negligent in its response to the distress signal from their capsized vessel. They argued that the Coast Guard broadcasted incorrect information about the vessel in distress and did not deploy the closest helicopter for the rescue mission.The United States Court of Appeals for the Third Circuit affirmed the lower court's dismissal of the case, stating that the United States was immune from such a suit. According to the court, the plaintiffs failed to show how the Coast Guard's alleged negligence "increased the risk of physical harm" to Greenberg. The court noted that under the "Good Samaritan" doctrine, the Coast Guard would only be liable if its actions increased the risk of harm or if harm was suffered because of the plaintiffs' reliance on the Coast Guard. In this case, the court found that even if the Coast Guard had done nothing, the outcome would have been the same, thus the Coast Guard did not increase the risk of harm to Greenberg.Furthermore, the court denied the plaintiffs' motion for leave to amend their complaint, stating it would be futile as they had not identified any set of facts that could demonstrate how the Coast Guard's actions increased the risk of physical harm to Greenberg. View "Avena v. Avena" on Justia Law