Justia Government & Administrative Law Opinion Summaries

In a consolidated action before the United States Court of Appeals for the Third Circuit, several parties, including PJM Power Providers Group, Electric Power Supply Association, and Pennsylvania Public Utility Commission, challenged a tariff filed by PJM Interconnection, L.L.C., concerning energy resources subject to price mitigation in interstate capacity auctions. The revised tariff, which took effect by operation of law in 2021, was the outcome of a deadlock between the Federal Energy Regulatory Commission (FERC) commissioners. The court found that the deadlock was to be treated as an affirmative order by the FERC, allowing for judicial review under Section 205(g) of the Federal Power Act (FPA). The court held that it was required to review the FERC order under the same deferential standards set forth in the FPA and the Administrative Procedure Act. The court’s review included the entire record, including the deadlock commissioners' written statements explaining their reasoning. Upon review, the court denied all three petitions, holding that FERC’s acceptance of PJM’s tariff was neither arbitrary nor capricious and was supported by substantial evidence in the record. View "Electric Power Supply Associat v. FERC" on Justia Law

In this consolidated action, the United States Court of Appeals for the Third Circuit reviewed a case concerning the Federal Energy Regulatory Commission's (FERC) acceptance of a tariff filed by PJM Interconnection, L.L.C. (PJM), which took effect by operation of law in 2021. The tariff was at the center of a dispute over whether state-subsidized energy resources should be subject to price mitigation in interstate capacity auctions. Petitioners – the PJM Power Providers Group (P3), the Electric Power Supply Association (EPSA), and the Pennsylvania Public Utility Commission and Public Utilities Commission of Ohio (State Entities) – sought review under Section 205(g) of the Federal Power Act (FPA), a provision allowing for review of FERC's action by inaction. The court held that its review of FERC action, whether actual or constructive, proceeds under the same deferential standards set forth in the FPA and Administrative Procedure Act. The court further held that its review properly encompasses the Commissioners’ statements setting forth their reasons for approving or denying the tariff filing. After reviewing the petitions, the court denied all three, finding FERC’s acceptance of PJM’s tariff was neither arbitrary nor capricious and was supported by substantial evidence in the record. View "Pennsylvania Public Utility Co v. FERC" on Justia Law

The Supreme Court of the State of Colorado reviewed a case involving a dispute over the methodology for implementing Tax Increment Financing (TIF) under Colorado's Urban Renewal Law (URL). The respondents, collectively known as AURA, argued that the methodology applied by the Colorado State Property Tax Administrator and the Arapahoe County Assessor was in violation of the URL because it differentiated between direct and indirect benefits when adjusting the base and increment values of blighted property in urban renewal areas. They contended that this methodology deprived urban renewal authorities of property tax revenues they should receive due to enhanced market perceptions of properties located in a TIF plan. The court of appeals agreed with AURA and reversed the district court's summary judgment favoring the Assessor. However, the Supreme Court held that the Administrator's methodology does not violate the URL. The URL does not prescribe a specific methodology but gives the Administrator broad authority to determine how to calculate and proportionately adjust the base and increment values. The court concluded that the Administrator's differentiation between direct and indirect benefits does not conflict with the URL, and therefore, reversed the portion of the division’s judgment concerning the Administrator’s methodology and affirmed that the district court correctly entered summary judgment. View "Kaiser v. Aurora Urban Renewal Authority" on Justia Law

In this case, the plaintiff, Jason Lambro, worked as a studio technician for the Voice of America (VOA), a federal agency, under a series of contracts. Lambro alleged that he should have been classified as an employee under the Fair Labor Standards Act (FLSA) and thus entitled to benefits such as overtime pay. The United States Court of Appeals for the Federal Circuit held that the FLSA itself, through its definitional provisions, provides the applicable standard for recognizing an employment relationship for FLSA purposes. Therefore, the court had to evaluate whether Lambro was employed by VOA under the FLSA's own standard for being employed. The court rejected the lower court's conclusion that the FLSA does not cover a person asserting coverage as a federal government employee unless a congressional authorization outside the FLSA creates the asserted employment relationship with the federal government. The court vacated the lower court’s dismissal and remanded the case for further proceedings. View "Lambro v. United States" on Justia Law

In this case from the Supreme Court of North Dakota, Daynen Hoover contested a district court judgment that affirmed a decision by the North Dakota Department of Transportation (Department) to suspend his driving privileges for 91 days. This penalty was the result of Hoover being arrested for being in control of a motor vehicle while under the influence of alcohol, with a blood alcohol concentration of .085 percent by weight. The Department conducted an administrative hearing by video conference, during which they introduced eight foundational exhibits from the State Crime Laboratory. Hoover objected to this on the grounds that he and his counsel did not have copies of these exhibits to review and analyze. Despite these objections, the hearing officer admitted the exhibits and the Department subsequently suspended Hoover's driving privileges for 91 days.On appeal, the Supreme Court of North Dakota reversed the district court's decision. The court concluded that the procedure used by the Department, which admitted exhibits into evidence without providing Hoover a meaningful opportunity to examine them, deprived him of a fair hearing. The court noted that the Department's notice of information did not offer copies of the exhibits or specifically identify which documents maintained by the Department or available on the attorney general's website would be introduced at the hearing. The court found that this violated the requirement for parties to be afforded an opportunity to examine exhibits before they are admitted into evidence. Therefore, the court ruled that the Department's procedures did not comply with state law and substantially prejudiced Hoover's procedural rights. The court's decision emphasized the importance of a party's ability to examine exhibits introduced against them as a critical procedural protection in adjudicative proceedings. View "Hoover v. NDDOT" on Justia Law

In the case before the Supreme Court of the State of Illinois, the City of Rock Falls filed a petition against Aims Industrial Services, LLC. The petition sought to enforce compliance with a City ordinance requiring the replacement of a private sewage disposal system with a connection to the City’s public sewage disposal system upon the sale or transfer of any property within the City limits. The trial court determined it would be inequitable to grant the City an injunction and denied the City’s petition. The appellate court reversed this decision, holding that the trial court erred in considering the equities when deciding whether to grant the injunction, as the City sought enforcement of an ordinance that specifically authorized injunctive relief.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court, stating that when a statute or ordinance expressly authorizes injunctive relief, the court has no discretion to refuse to grant the injunctive relief once a violation of the statute or ordinance has been established. The Supreme Court clarified that in such cases, balancing of the equities is not necessary since a violation of the statute or ordinance implies a harm to the public. Therefore, the trial court's refusal to grant the injunction based on its own balancing of the equities was an error. View "City of Rock Falls v. Aims Industrial Services, LLC" on Justia Law

In the state of Illinois, a group of active and retired members of local police and firefighter pension funds filed a complaint against the Governor and other officials, challenging the constitutionality of Public Act 101-610. This Act amended the Illinois Pension Code and consolidated all local police and firefighter pension fund assets into two statewide pension investment funds. The plaintiffs claimed the Act violated two provisions of the Illinois Constitution: the pension protection clause and the takings clause. They argued that the Act diminished their pension benefits by diluting their voting power and control over investment decisions, and by imposing costs associated with the Act's implementation, including repayment of any transition loans. The Supreme Court of Illinois disagreed with the plaintiffs, affirming the lower courts' decisions. The court ruled that the Act does not violate the pension protection clause because the ability to vote in local pension board elections and control local pension fund investments are not constitutionally protected benefits. They also ruled that the Act does not violate the takings clause because the plaintiffs do not have a private property right in the funds that are to be transferred to the new statewide funds. The Act only changes how local fund assets are managed and invested without affecting the ultimate use of those assets to pay the benefits of local fund members. Thus, the Act remains in effect. View "Arlington Heights Police Pension Fund v. Pritzker" on Justia Law

In the case before the Supreme Court of Alabama, Emma Louie, Garry Rice, and Toice Goodson, employees of the Greene County Board of Education, sought a writ of mandamus directing the Greene Circuit Court to enter a summary judgment in their favor, asserting that they are protected by State-agent immunity. The claims against them were brought by Ester Eaton and Anthony Eaton, who alleged negligence and loss of consortium after Ester Eaton, a substitute teacher, was attacked while supervising a classroom of students in the Alternative Program and in-school suspension (ISS). The defendants argued that their supposed violations of school policies were in fact based on discretionary decisions, not violations of specific, mandatory rules, thus entitling them to State-agent immunity.The Supreme Court of Alabama agreed with the defendants, ruling that the school guidelines in question were not specific, nondiscretionary rules, but rather allowed for administrative discretion. As such, the court found that the defendants' actions fell within the scope of their discretion as state agents, and they were therefore entitled to State-agent immunity. Consequently, the court granted the petition for a writ of mandamus and directed the trial court to enter a summary judgment in favor of the defendants. View "Ex parte Louie" on Justia Law

The defendant, Tristan T. Horne, was charged with attempted possession of a firearm by a prohibited person. As part of a plea agreement, Horne was admitted into a problem-solving court program (Wellness Court) designed to assist defendants with mental health diagnoses. The program defers sentencing and provides treatment, supervision, and judicial oversight. Successful completion of the program may result in the defendant being allowed to withdraw their plea and have their charges dismissed. However, if the participant is removed from the program or withdraws before successful completion, the conviction stands and the case proceeds to sentencing.Throughout Horne's participation in the program, he repeatedly violated program requirements. These violations included missed drug tests, dishonesty with probation officers, not completing community service hours ordered by the District Court, failing to successfully complete multiple residential treatment programs, testing positive for marijuana, removing his court-ordered GPS monitoring device, and failing to report to jail as ordered after leaving a treatment program. Following these violations, the State moved to remove Horne from the program. The District Court accepted Horne's admission to the violations and removed him from the program. Subsequently, Horne was sentenced to a term of imprisonment.On appeal, Horne challenged his removal from the program, the fact that the District Court did not order a presentence investigation before sentencing him, and the length of his sentence. The Nebraska Supreme Court affirmed the District Court's decision, finding no reversible error. It held that the District Court did not abuse its discretion in removing Horne from the program given his multiple failures to comply with program requirements. The Supreme Court also held that the District Court did not plainly err in not ordering a presentence investigation before sentencing Horne. Lastly, the Supreme Court found that the District Court did not abuse its discretion in sentencing Horne. View "State v. Horne" on Justia Law

The Supreme Court of Mississippi examined whether a school district was entitled to funds recovered by a county from the bankruptcy proceedings of a delinquent taxpayer. The taxes, if collected normally, would have been used to fund the school district. However, the county board of supervisors had anticipated the delinquency and adjusted the levy of ad valorem taxes to compensate, ensuring the school district did not experience a shortfall. The school district argued it was entitled to its original portion of the recovered bankruptcy funds, but the county claimed that this would result in a double recovery outside the statutory scheme for public school funding. The Supreme Court of Mississippi found in favor of the county, ruling that the recovery of delinquent taxes through bankruptcy proceedings is outside the statutory funding scheme for public school districts in Mississippi. The court found that the school district was not entitled to receive delinquent taxes recovered years later in bankruptcy proceedings and reversed and remanded the lower court's award to the school district. View "Clarke County, Mississippi v. Quitman School District" on Justia Law