Justia Government & Administrative Law Opinion Summaries

The United States Court of Appeals for the Eighth Circuit affirmed the sentences of Theodore Browne and Karley Ann Smith, both of whom had pled guilty to conspiring to distribute 50 grams or more of methamphetamine. Browne claimed that the district court erred in determining that he transported 10 pounds of meth, which influenced his base offense level. However, the Appeals Court ruled that the district court's approximation of the drug quantity, based on witness testimonies, was not clearly erroneous. Browne also argued that the district court wrongly applied a 4-level role enhancement, contending that there was insufficient evidence to show he was an "organizer or leader" of the conspiracy. The Appeals Court disagreed, ruling that the district court's finding was not clearly erroneous based on witness testimonies. Smith argued that the district court abused its discretion by considering late-filed evidence in the government’s sentencing memorandum, which resulted in the imposition of an obstruction enhancement and the denial of an acceptance-of-responsibility reduction. The Appeals Court ruled that Smith had sufficient time to review and respond to the challenged exhibits, and that the district court did not err in finding obstruction of justice and rejecting the acceptance-of-responsibility reduction. View "United States v. Browne" on Justia Law

The Supreme Court of the State of Hawai'i affirmed the judgment of the Intermediate Court of Appeals upholding the conviction of Michael Pickell for operating a vehicle under the influence of an intoxicant. The case centered around the legality of a traffic stop initiated by a Maui County police officer who observed Pickell executing a U-turn at a highway intersection with left turn only markings and signage but no signage explicitly prohibiting U-turns. Pickell argued that in the absence of an express sign prohibiting U-turns, as required by Hawai'i Revised Statutes (HRS) § 291C-82(c), the officer lacked reasonable suspicion to make the traffic stop. The court held that the Maui County ordinance, which requires drivers to follow the directional movements exhibited on markings and signage at intersections, was neither preempted by HRS § 291C-82(c) nor in conflict with it. Therefore, the officer had reasonable suspicion to initiate the traffic stop based on a violation of the Maui County ordinance, and the motion to suppress evidence from the stop was properly denied. View "State v. Pickell" on Justia Law

In this case, the defendant, Christopher De Leon Guerrero, was convicted on two counts of attempted enticement of a minor in violation of 18 U.S.C. § 2422(b) and 18 U.S.C. § 2, and was sentenced to ten years in prison and five years of supervised release. Guerrero appealed his conviction and sentence.Guerrero's conviction was based on his online conversations with a fictional 13-year-old girl named "Emily," who was actually a federal agent. He made plans to meet "Emily" at Andersen Air Force Base for sexual activities. Guerrero argued that he could not be charged under Guam law for actions that took place on a federal enclave, Andersen Air Force Base. The United States Court of Appeals for the Ninth Circuit disagreed, citing a precedent set in United States v. Lopez.The court affirmed Guerrero’s convictions under § 2422(b) by referencing another predicate offense, not specified in the indictment, with which he could have been charged. They concluded that both of Guerrero’s convictions could be supported by § 13.10, the Guam criminal attempt statute.As for the sentence, the court agreed with both parties that Guerrero’s sentence should be reversed, vacated, and remanded to the district court for reconsideration of three special conditions imposed on his supervised release. These conditions were that Guerrero must not go to places where children under the age of 18 are likely to be, must not view or possess any visual depiction of sexually explicit conduct, and must participate in a sex offense-specific treatment program.The court affirmed the convictions but reversed, vacated, and remanded the sentence to the district court for reconsideration of the three special conditions of supervised release. View "USA V. GUERRERO" on Justia Law

The case involves Brandon Peterson, an inmate at Washington County Jail (WCJ), who filed a lawsuit alleging violations of his constitutional rights by various jail officials. The United States Court of Appeals for the Eighth Circuit, reviewing the case, had to decide on numerous instances of alleged excessive force, failure to intervene, and deliberate indifference to serious medical needs, as well as constitutional and state law claims.The court found that on several occasions of alleged excessive force, the officers' actions were justified given Peterson's disruptive and threatening behavior. Consequently, the court granted qualified immunity to the officers involved in these incidents. In the case of the failure to intervene claims, the court decided that without an underlying constitutional violation, there can be no liability for failure to intervene, resulting in the officers being granted qualified immunity for these claims as well.On the issue of deliberate indifference to Peterson's mental health condition, the court found that the prison officials had made efforts to address his condition and had not acted with deliberate disregard for his health. Therefore, the court reversed the district court's denial of qualified immunity to the officials involved.Regarding Peterson's claim of being subjected to unconstitutional conditions of confinement, the court remanded the case to the district court for it to address this issue. The court also remanded the case to the district court to decide on the state law and Monell claims. As such, the Appeals Court reversed in part, dismissed in part, and vacated in part the district court's decision, remanding the case for further proceedings consistent with the court’s opinion. View "Peterson v. Heinen" on Justia Law

In the Supreme Court of the State of Alaska, the case involved a self-represented prisoner who sued the Department of Corrections (DOC) for intentional and negligent infliction of emotional distress. The prisoner alleged that DOC held him in administrative segregation (solitary confinement) for 504 days and that corrections officers denied him any meaningful opportunity to appeal or be heard regarding his segregation. The prisoner contended that the corrections officers’ actions amounted to extreme and outrageous conduct that caused him severe emotional distress. The superior court granted summary judgment in favor of DOC, reasoning that DOC’s conduct was not extreme and outrageous and that the prisoner’s distress was not severe enough to give rise to liability.On appeal, the Supreme Court of the State of Alaska concluded that the superior court abused its discretion in dismissing the prisoner's claim of intentional infliction of emotional distress. The Supreme Court reversed the superior court’s grant of summary judgment in DOC’s favor as to the prisoner’s intentional infliction of emotional distress claim. The Supreme Court also vacated the superior court’s order approving the attorney general’s certification that individual corrections officers acted within the scope of their employment, reversed the court’s denial of the prisoner’s request to compel certain discovery, and remanded for further proceedings consistent with this decision. However, the Supreme Court affirmed the superior court’s grant of summary judgment with respect to the prisoner’s negligent infliction of emotional distress claim. View "Watkinson v. State of Alaska" on Justia Law

In a dispute involving a power grid operator, PJM Interconnection, L.L.C., and the Federal Energy Regulatory Commission (FERC), the United States Court of Appeals for the Sixth Circuit ruled that the Chairman of FERC exceeded his authority by seeking a remand of a ratemaking challenge without the support of other Commission members.The case originated when PJM filed a request to modify its existing rates for electricity reserves, arguing that the existing rates were unjust and unreasonable. Initially, FERC agreed and approved the new rates. However, after a change in FERC's composition and a unilateral decision by the Chairman to request a voluntary remand from the D.C. Circuit for reconsideration, FERC reversed its decision and found PJM's evidence insufficient.The Sixth Circuit's ruling focused on the procedural irregularity, specifically the Chairman's unilateral decision to seek a remand, which it deemed exceeded his administrative authority. The court stated that a quorum majority must decide the Commission’s policy and dealings with the outside world, and the Chairman acting alone does not meet this requirement. As such, the court vacated the part of FERC's rehearing order that claimed the Chairman had this unilateral authority and remanded the matter back to FERC to address this issue.The court did not address the substantive issue of whether FERC's reversal on the ratemaking decisions was arbitrary and capricious. It noted that any interested party may renew a petition to challenge that decision after FERC resolves the procedural issue. View "PJM Power Providers Grp. v. FERC" on Justia Law

In a case involving the Federal Energy Regulatory Commission (FERC) and the Electric Power Supply Association and PJM Power Providers Group (collectively, PJM), the United States Court of Appeals for the Sixth Circuit had to address two questions. The first was whether the Chairman of FERC exceeded his authority when he moved for a remand of a ratemaking challenge without the support of any other members of the Commission, and the second was whether FERC's underlying ratemaking decisions were arbitrary and capricious.The case arose from PJM's request to FERC to raise the reserve price cap for electricity from $850 to $2,000 per megawatt hour and to replace the flat $300 per megawatt hour cap after Step 1 with a downward sloping price schedule. Initially, FERC agreed with PJM that the existing price cap and stepwise demand curve were unjust and unreasonable. However, after a change in the composition of the FERC, the Commission sought a voluntary remand from the D.C. Circuit to reconsider its prior decisions. The D.C. Circuit granted the unopposed motion for remand. On remand, the Commission reversed its previous decision and found PJM's evidence insufficient to show that the price caps for reserves and stepwise demand curve were unjust and unreasonable.PJM and others sought rehearing before the Commission, citing a procedural irregularity - the Chairman had directed FERC's Solicitor to seek remand without first informing the other Commissioners - and challenging the substance of the agency’s shift in views. The Commission rejected the request for rehearing but issued a modified order, reaching the same result, and reasoning that Chairman Glick had the unilateral authority to make the remand motion.The Court of Appeals for the Sixth Circuit held that the Chairman of FERC exceeded his legal authority when he requested a remand in the name of the Commission on his own. The court vacated part of the Commission’s order claiming the Chairman had this unilateral authority and remanded the case back to the Commission to decide what, if anything, it could or would have done differently in response to this legal mistake. The court did not rule on whether FERC's underlying ratemaking decisions were arbitrary and capricious, leaving it to the Commission to first resolve the legal mistake. View "Electric Power Supply Ass'n v. FERC" on Justia Law

Erik Bertaud, who suffered serious injuries when a tree branch fell on his head, applied for disability insurance benefits and supplemental security income from the Social Security Administration. His application was denied, and he appealed. The Appeals Council remanded the case twice, but after the third denial, Bertaud's request for review was denied, making the ALJ's decision the final decision of the Commissioner. Bertaud then sought judicial review, arguing that the ALJ had failed to develop the record of his disability, pointing to over 800 pages of new medical evidence. The district court denied Bertaud's motion for summary judgment and affirmed the Commissioner's decision, and Bertaud appealed to the United States Court of Appeals for the Seventh Circuit.The court held that although an ALJ has a duty to develop a full and fair record, this duty is limited when the claimant is represented by an attorney. The claimant's duty to submit evidence is ongoing and covers any additional related evidence they become aware of. The court noted that Bertaud was represented and his attorney had confirmed that the evidence was complete and supplemented the record when necessary. Therefore, the court concluded that the ALJ did not fail to develop Bertaud's medical record. The court affirmed the district court's decision denying Bertaud's motion for summary judgment and affirming the decision of the Commissioner. View "Bertaud v. O'Malley" on Justia Law

In this case, an accident occurred where Sara Spagnolini, a provider under the In-Home Supportive Services (IHSS) program, ran a stop sign and crashed into a car driven by Hanah Keren Samson Yalung. Yalung and four of her five children were seriously injured, and one child was killed. Yalung, individually and as an administrator of her deceased daughter's estate and guardian ad litem for her other children, sued the State of California, among others, for Spagnolini's negligence.The plaintiffs argued that the State was liable for Spagnolini's negligence as her employer or as a joint employer with Spagnolini's recipient under the IHSS program. The Superior Court of Tulare County, however, sustained the State's demurrer to the first amended complaint without leave to amend. The trial court did not find the statutory scheme made the State the employer or joint employer of IHSS providers for all purposes, noting that no cases held the State was an employer for purposes of vicarious liability.On appeal, the Court of Appeal of the State of California Fifth Appellate District affirmed the trial court's decision. The appellate court concluded that the IHSS statutes are incompatible with a finding of joint employment as a matter of law. The court found that while the State administers the IHSS program and has some oversight responsibilities, it does not control or direct the day-to-day tasks or activities of IHSS providers. Accordingly, the State could not be deemed an employer or joint employer for the purposes of vicarious liability. View "Yalung v. State of California" on Justia Law

The case involves the defendant, Jason Thomas Wilcox, who was taken into police custody for public intoxication under ORS 430.399, a noncriminal statute. During this process, the police seized and inventoried his backpack, discovering a butterfly knife. As Wilcox had a prior felony conviction, he was charged and convicted for being a felon in possession of a restricted weapon under ORS 166.270(2). Wilcox appealed, arguing that the seizure of his backpack was unlawful under Article I, section 9, of the Oregon Constitution. The Court of Appeals agreed, finding that the seizure was unlawful, and based its decision on a previous case, State v. Edwards.The Supreme Court of the State of Oregon vacated the decision of the Court of Appeals and remanded the case for further proceedings. The Supreme Court found that the Court of Appeals had erred in its analysis because it treated the seizure as a criminal one rather than an administrative one. The Court pointed out that when a person or their property is seized under ORS 430.399, the seizure is administrative, not criminal, and such seizures must comply with a different set of constitutional standards. The Court also clarified that the state’s interference with a person’s possessory or ownership interests constitutes a seizure, regardless of whether the person objects to the interference.The Supreme Court held that the seizure of the backpack was indeed a seizure. However, it did not decide whether the seizure was lawful, instead remanding the case to the Court of Appeals to determine whether ORS 430.399, or some other source of authority, authorized the seizure of defendant’s backpack and if so, whether that seizure was effectuated in accordance with the requirements of State v. Atkinson, which set the framework for assessing the constitutionality of an administrative search or seizure. View "State v. Wilcox" on Justia Law