Justia Government & Administrative Law Opinion Summaries

The case revolves around a dispute between two cities, Norwalk and Cerritos, both located in California. In 1974, Cerritos enacted an ordinance restricting commercial and heavy truck traffic to certain major arteries within the city. The ordinance was amended in 2019 and 2020, resulting in the removal of one of these arteries. Consequently, Norwalk sued Cerritos, arguing that the ordinance created a public nuisance by diverting extra truck traffic through Norwalk and thus causing various "adverse effects" linked to heavier traffic flow. Cerritos claimed immunity under Civil Code section 3482, which shields a city from public nuisance liability for actions "done or maintained under the express authority of a statute". The Court of Appeal of the State of California Second Appellate District found that the Vehicle Code explicitly authorized cities to regulate the use of their streets by commercial or heavy vehicles. Therefore, the court held that Cerritos was immune from liability for the public nuisance of diverting traffic into Norwalk. The court stated that the immunity conferred by Civil Code section 3482 applied not only to the specific act expressly authorized by the statute, but also to the consequences that necessarily stemmed from that act. The court affirmed the judgment in favor of Cerritos. View "City of Norwalk v. City of Cerritos" on Justia Law

A group of current and former inmates, or their representatives, filed a class action lawsuit against Kate Brown, the Governor of Oregon, and Patrick Allen, the Director of the Oregon Health Authority, claiming that the state's COVID-19 vaccine rollout plan, which prioritized corrections officers over inmates, violated their Eighth Amendment rights. The defendants moved to dismiss the claim, asserting immunity under the Public Readiness and Emergency Preparedness (PREP) Act. The district court denied the motion, and the defendants appealed.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision, finding that the defendants were immune from liability for the vaccine prioritization claim under the PREP Act. The court held that the statutory requirements for PREP Act immunity were met because the "administration" of a covered countermeasure includes prioritization of that countermeasure when its supply is limited. The court further concluded that the PREP Act's provisions extend immunity to persons who make policy-level decisions regarding the administration or use of covered countermeasures. The court also held that the PREP Act provides immunity from suit and liability for constitutional claims brought under 42 U.S.C. § 1983, even if those claims are federal constitutional claims. View "MANEY V. BROWN" on Justia Law

In 2022, Oregon voters approved Ballot Measure 113, amending the state constitution to disqualify any state legislator who accumulates 10 or more unexcused absences during a legislative session from holding office "for the term following the election after the member’s current term is completed." The Secretary of State interpreted this to mean that the disqualification applies to a legislator’s immediate next term. However, a group of legislators challenged this interpretation, arguing that the disqualification should apply one term later.The Supreme Court of the State of Oregon held that the measure's disqualification applies to the legislator’s immediate next term of office. The Court found that the text of the amendment was capable of supporting the Secretary's interpretation. This interpretation was also supported by the ballot title and the voters’ pamphlet, which repeatedly described the disqualification as occurring immediately following the legislator’s current term. The Court concluded that voters would have understood the amendment in light of these materials. Therefore, the Court upheld the Secretary's rules implementing the amendment. View "Knopp v. Griffin-Valade" on Justia Law

In this case, the appellant, Bjay Nagel, who was employed as a caretaker by Sand Creek Country Club, broke his ankle while working. He had been drinking alcohol prior to the accident. The Wyoming Department of Workforce Services, Workers' Compensation Division initially awarded benefits but later denied further benefits after discovering that Nagel was intoxicated at the time of his injury. The Wyoming Office of Administrative Hearings (OAH) upheld the Division's denial of benefits, finding that Nagel's intoxication was a substantial factor causing his injury. Nagel appealed the decision, claiming that the OAH's decision was contrary to substantial evidence, arbitrary, capricious, or otherwise not in accordance with the law.The Supreme Court of Wyoming affirmed the decision of the lower court. The Court found that there was substantial evidence supporting the OAH's decision that Nagel's intoxication was a substantial factor causing his injury. The Court also found that the decision was not arbitrary or capricious because there was a rational basis for it, and the decision was in accordance with the law. Nagel's intoxication at the time of his injury was established by a blood alcohol content test which showed a level of .183%. Furthermore, an expert opinion was provided which stated that it was more likely than not that Nagel's intoxication was a substantial factor causing his injury. View "Nagel v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

Eric Salvador Pena, a convicted felon, sold a firearm to a confidential informant working for the Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”). He was subsequently arrested for possession of a firearm by a convicted felon and pleaded guilty. At sentencing, the district court applied an enhanced offense level as the firearm sold was capable of accepting a large-capacity magazine, offering a guideline range of 51 to 63 months of incarceration. Pena objected, arguing that the firearm could not function with a fully loaded magazine and therefore did not meet the definition of being "capable of accepting a large capacity magazine".The United States Court of Appeals for the Fifth Circuit disagreed with Pena's argument. It held that the firearm in question met the definition because it could accept and function with a magazine containing more than 15 rounds of ammunition, even though it had jammed during a test when fully loaded. The court also determined that the district court had not erred procedurally or substantively in sentencing. It affirmed the district court’s decision to impose a 63-month sentence of incarceration and 3 years of supervised release. View "USA v. Pena" on Justia Law

In the case before the Court of Appeal of the State of California First Appellate District Division Two, the appellant, Debra Abney, challenged the decision of the State Department of Health Care Services and the City and County of San Francisco to consider money garnished from her Social Security payments as income for the purposes of determining her eligibility for benefits under Medi-Cal.Abney's Social Security payments were being reduced by nearly $600 each month to satisfy a debt she owed to the IRS. The authorities considered this garnished money as income, which led to Abney being ineligible to receive Medi-Cal benefits without contributing a share of cost. Abney argued that the money being garnished was not income “actually available to meet her needs” under the regulations implementing the Medi-Cal program.The trial court rejected Abney's argument, and she appealed. The Court of Appeal affirmed the trial court's decision. The Court of Appeal held that the tax garnishment was "actually available" to meet Abney's needs because it benefitted her financially by helping to extinguish her debt to the IRS. Therefore, the garnished money was correctly considered as income for the purpose of calculating her eligibility for the Medi-Cal program. View "Abney v. State Dept. of Health Care Services" on Justia Law

Four Iranian nationals, who had previously completed mandatory military service in Iran's Islamic Revolutionary Guard Corps (IRGC), were denied visas to enter the United States. Their family members, three U.S. citizens and one lawful permanent resident, filed a suit against the President and several federal officials responsible for visa applications. They alleged that the defendants unlawfully deprived visa applicants the opportunity to establish eligibility for terrorism-related inadmissibility grounds (TRIG) exemptions, violating their rights under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The district court dismissed the case under the doctrine of consular nonreviewability, which bars judicial review of consular decisions. The Plaintiffs appealed, and the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the doctrine of consular nonreviewability applied, and that the plaintiffs failed to show any evidence of bad faith that could overcome this doctrine. The court also held that the applicants were not entitled to any more explanation for their visa denials than the citation to the section of the law on which the denial was based. View "Pak v. Biden" on Justia Law

In the case of City of St. Louis and Heather Taylor (“Appellants”) versus State of Missouri (“State”), the Supreme Court of Missouri analyzed Senate Bill No. 26 (“SB 26”) that was challenged for being unconstitutional. SB 26, introduced in December 2020 and signed into law in July 2021, contained 88 sections related to public safety, including procedures for imposing discipline on law enforcement officers and provisions for the offense of “unlawful traffic interference.”Appellants argued that SB 26 violated the Missouri Constitution on several grounds, including that it violated the original-purpose and single-subject rules, that it created an unfunded mandate, that it imposed additional duties on officers and employees of a constitutional charter city, that it used public funds for private purposes, and that it created unequal treatment between law enforcement officers and other city employees.The Supreme Court of Missouri found that the City had sufficiently pleaded the elements of a Hancock Amendment violation, which prohibits the state from requiring new or expanded activities by counties and other political subdivisions without full state financing. Therefore, the circuit court's judgment was reversed on this point and the case was remanded for further proceedings.However, the court affirmed the judgment with respect to Appellants' other points. It found that SB 26 had the same purpose as enacted as introduced, did not impose new duties on city employees or allocate funds for public purposes, and had a rational basis for treating law enforcement officers differently from other city employees. The court also found that SB 26 did not violate the original-purpose and single-subject rules, did not impose additional duties on officers and employees of a constitutional charter city, did not use public funds for private purposes, and did not create unequal treatment between law enforcement officers and other city employees. View "City of St. Louis v. State" on Justia Law

An inmate in Texas, Raul Gerardo Favela, Jr., alleged that prison officials had ignored warnings and failed to prevent him from being assaulted by another inmate. Favela sued several employees of the Texas Department of Criminal Justice (TDCJ) under 42 U.S.C. § 1983, claiming that their failure to protect him violated his constitutional rights. However, the district court granted summary judgment in favor of the defendants, stating that Favela had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA). The United States Court of Appeals for the Fifth Circuit reversed the decision of the district court, finding that the summary judgment was inappropriate. Favela's declaration that he had filed and timely submitted grievances relating to his claims was found to be sufficient to establish a genuine issue of material fact, thereby meeting his burden to counter the defendant's prima facie case. The court concluded that the matter of the credibility of Favela's statement was a matter for trial, and not for summary judgment. The case was remanded for further proceedings. View "Favela v. Collier" on Justia Law

In this case, the City of Laramie, Wyoming, sued the University of Wyoming and its Board of Trustees, challenging the drilling and operation of certain water wells. The city argued that the university was in violation of a 1965 deed covenant prohibiting the drilling of one of the wells and was also in violation of a city ordinance. The city also claimed that legislation exempting the university from this city ordinance was unconstitutional. The district court dismissed some of the city's claims and granted summary judgment in favor of the university on the remaining claims. The Supreme Court of Wyoming affirmed the lower court's decision. The court held that the university was protected by sovereign immunity from the city's attempts to enforce the deed covenant. It also held that the state law exempting the university from the city ordinance was constitutional. The court further noted that the law precluded the city from enforcing its ordinance against the university. View "City of Laramie, Wyoming v. University of Wyoming" on Justia Law