Justia Government & Administrative Law Opinion Summaries

The case centers on the City of San José’s attempt to address a substantial unfunded liability in its employee retirement plans. The City, obligated by its charter and state law to maintain actuarially sound pension systems for its employees, decided to refinance this unfunded liability by issuing pension obligation bonds. The proposed bonds would allow the City to pay down the liability at a potentially lower interest rate, thereby aiming to relieve future budgetary pressures. The Howard Jarvis Taxpayers Association and others challenged the plan, arguing that issuing these bonds would create new municipal debt exceeding current annual revenues and, under the California Constitution’s local debt limitation, would require approval by two-thirds of the City’s voters.The Santa Clara County Superior Court found in favor of the City, ruling that the unfunded pension liability was an obligation imposed by law and thus fell within an exception to the local debt limitation. The California Court of Appeal affirmed, though it reasoned that the bonds would not create new debt because the obligation already existed in the form of the unfunded liability.The Supreme Court of California reviewed the case and affirmed the judgment of the Court of Appeal. The Court held that, even if the bonds were considered to create new debt, the City’s obligation to address its unfunded actuarial liability is an obligation imposed by law, not a voluntary undertaking. Therefore, the exception to the local debt limitation applies, and voter approval is not required for the issuance of the pension obligation bonds. The Court clarified that the local debt limitation does not restrict the City’s discretion in choosing how to fulfill its legally imposed pension funding obligations. View "City of San Jose v. Howard Jarvis Taxpayers Assn." on Justia Law

The case involves an individual who left his Florida residence in August 2018 to care for his terminally ill brother, a tenant in a New York City Mitchell-Lama apartment. After the brother’s death in March 2020, the petitioner sought succession rights to the apartment, which required him to prove that the apartment was his primary residence for at least one year prior to his brother’s death. The petitioner submitted various documents, including income certifications, power of attorney forms, and certain public assistance records. However, some materials listed his Florida address, and much of his supporting documentation either fell outside the relevant one-year period or was not addressed to the apartment in question.The housing company denied his application, concluding that he failed to establish primary residency during the required time. The New York City Department of Housing Preservation and Development (HPD) upheld this decision after an administrative appeal, finding the evidence insufficient. The petitioner then challenged the agency’s determination through a CPLR article 78 proceeding. The Supreme Court annulled the agency’s decision and granted succession rights, ruling the denial irrational. On appeal, the Appellate Division reversed, holding that the agency’s denial had a rational basis, especially given the petitioner’s failure to supply certain key documents such as New York State tax returns or proof of exemption.The New York Court of Appeals affirmed the Appellate Division’s decision. The Court held that, under the applicable regulations, the agency’s determination that the petitioner failed to prove the apartment was his primary residence for the required period was supported by a rational basis. The Court emphasized that the agency’s decision was neither arbitrary nor capricious, and the evidence provided by the petitioner did not meet the burden required to establish primary residency for succession rights. The order dismissing the petition was affirmed. View "Matter of Mantilla v New York City Dept. of Hous. Preserv. & Dev." on Justia Law

A resident who lived within a business and parking improvement district in Seattle requested records relating to district operations, including staff compensation, budgets, and meeting minutes. The district was managed by DBIA Services, a private nonprofit corporation that provided services funded almost entirely by assessments on local property owners, collected by the City of Seattle. DBIA managed key district programs, including public safety, sanitation, and economic development, and often identified itself as acting on behalf of the district. When the resident could not obtain all requested information, particularly staff compensation details, he brought suit alleging that DBIA was subject to Washington’s Public Records Act.In King County Superior Court, both parties moved for summary judgment. The court found that DBIA Services and the district were not a single entity and that DBIA was not the functional equivalent of a government agency under the Public Records Act, granting judgment for DBIA. The Washington Court of Appeals affirmed, using an abuse of discretion standard on summary judgment.The Supreme Court of the State of Washington reviewed the case de novo and concluded that DBIA Services is the functional equivalent of a government agency under the Telford test, considering factors such as the governmental nature of DBIA’s functions, the overwhelming public funding, and the risk that denying access would frustrate government transparency. The Supreme Court held that DBIA is subject to the Public Records Act, reversed the Court of Appeals, and remanded the case for further proceedings. The court also granted the petitioner’s request for attorney fees on appeal, to be determined by the trial court. View "Horvath v. DBIA Services" on Justia Law

Florida PACE Funding Agency initiated a proceeding in the Second Judicial Circuit to validate the issuance of $5 billion in bonds for financing certain property improvements under the PACE Act. The agency complied with statutory notice requirements, and a hearing was held where State Attorneys from the Second, Seventh, and Ninth Circuits were represented. No party objected to the entry of final judgment validating the bonds, and the judgment became final without any appeal. Over a year later, various governmental entities—including state attorneys, counties, and tax collectors (most of whom did not participate in the original proceedings)—filed motions under Florida Rule of Civil Procedure 1.540, seeking relief from the judgment, raising arguments such as lack of jurisdiction, due process violations, and alleged surprise.The circuit court allowed discovery and held an evidentiary hearing, after which it denied all motions for relief from judgment. For the parties who had not appeared previously, the court found that rule 1.540 did not apply to bond validation judgments due to the strict finality requirements of chapter 75, Florida Statutes, and that the motions were untimely and insufficient. For the state attorneys who had participated, the court concluded they were procedurally barred from seeking relief under rule 1.540 because it could not substitute for appellate review.On appeal, the Supreme Court of Florida reviewed whether rule 1.540 applies to final judgments in bond validation proceedings under chapter 75. The court held that chapter 75’s finality language—specifically section 75.09—precludes the use of rule 1.540 to collaterally attack such judgments after the time for appeal has expired. The court concluded that the statutory scheme is exclusive, and the rules of civil procedure do not override the statute. Accordingly, the Supreme Court of Florida affirmed the circuit court’s denial of the motions for relief from judgment. View "State Attorneys for the Second, Seventh and Ninth Judicial Circuits v. Florida Pace Funding Agency" on Justia Law

Fairville Township decided to remove two culvert crossings, known as Crossings 2 and 3, from a township roadway. These culverts had existed prior to construction of the Oak Creek Drain, a flood control project built by the Wells County Water Resource District in the late 1980s, which had incorporated the culverts into its design. After the Township removed the crossings and reconstructed the roadway, the Water District determined that this constituted an obstruction to the drain and would adversely affect local agricultural land and infrastructure. The Water District ordered the Township to reconstruct the crossings, and when the Township did not comply, the District reinstalled the culverts itself.The Water District issued orders to assess the costs of reinstalling the culverts against Fairville Township, citing its statutory authority under N.D.C.C. § 61-16.1-51. The District concluded that the Township was responsible for the obstruction and directed Wells County to levy the assessment against the Township. Fairville Township appealed these assessment orders to the District Court of Wells County. After briefing, the district court reversed the Water District’s assessment orders, finding that the statute applied only to private landowners or tenants, not to governing bodies such as townships, and that the Water District’s actions were arbitrary, capricious, and unreasonable.The Supreme Court of North Dakota reviewed the district court’s decision under a limited standard, independently considering whether the Water District acted arbitrarily, capriciously, or unreasonably. The Supreme Court held that N.D.C.C. § 61-16.1-51 only authorizes water resource boards to assess costs against the property of a responsible landowner, and the Water District failed to establish that the Township was a landowner or that costs were assessed against its property. The Supreme Court affirmed the district court’s reversal of the Water District’s assessment orders. View "Fairville Township v. Wells Cty. Water Resource District" on Justia Law

A firefighter employed by a city filed a legal action seeking a declaration that a city ordinance requiring firefighters to live within a certain distance of a fire station was invalid. He argued that state law, specifically KRS 311A.027(1), prohibits publicly funded emergency medical service first response providers from imposing residency requirements on employees or volunteers, and that the city's firefighters, who are certified to provide emergency medical services, fall within this category.The McCracken Circuit Court granted summary judgment in favor of the city, holding that the statute in question was not intended to apply to firefighters, but rather to those whose primary duties are as emergency medical service first response providers. The trial court reasoned that firefighters are primarily governed by a different chapter of Kentucky law, which does not prohibit residency requirements. The Kentucky Court of Appeals affirmed this decision, agreeing with the trial court’s interpretation and analysis.On discretionary review, the Supreme Court of Kentucky examined whether the statute applies to the city’s fire department and its personnel. The Court held that KRS 311A.027(1) applies to institutions, not individuals, and that the term “emergency medical service first response provider” as used in the statute refers to entities that provide ambulance services and are regulated as such under Kentucky law. Because the city’s fire department does not operate ambulances or provide ambulance services, it is not an emergency medical service first response provider within the meaning of the statute. Therefore, the residency ordinance is not preempted by KRS 311A.027(1). The Supreme Court of Kentucky affirmed the decision of the Court of Appeals. View "TORIAN V. CITY OF PADUCAH, KENTUCKY" on Justia Law

The case arises from a procurement process initiated by Idaho’s Division of Purchasing to select a contractor to provide behavioral health and substance abuse services for the Idaho Department of Health and Welfare. Carelon Behavioral Health, Inc. was initially selected as the winning bidder. However, the other two bidders, Magellan Healthcare and United Behavioral Health (Optum), challenged Carelon’s eligibility, arguing that Carelon had previously been paid by the State for services used to prepare the specifications of the contract, which would bar it from bidding under Idaho Code section 67-9230(8). A determinations officer reviewed the matter and found that Carelon's prior work did influence the contract specifications, rendering it ineligible. The Director of Administration adopted this recommendation, rescinded the intent to award the contract to Carelon, and ultimately awarded it to Magellan.Following this, Carelon filed a complaint in the District Court of the Fourth Judicial District seeking declaratory relief and a writ of mandate to overturn the Director’s decision and reinstate its bid. The district court dismissed the complaint for lack of subject matter jurisdiction, reasoning that Carelon’s claims were, in substance, a request for judicial review of the Director’s procurement decision, which is expressly precluded by the State Procurement Act unless the case arises from a contested case hearing. The court also rejected Carelon’s claims for a writ of mandate and its constitutional challenges to the statute.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s dismissal. The Court held that the State Procurement Act prohibits judicial review of procurement decisions made outside of contested case hearings and that Carelon’s claims could not be recast as an original declaratory judgment action to circumvent this limitation. The Court also found that the statutory bar on judicial review does not violate the separation of powers under the Idaho Constitution and that section 67-9230(8) is not unconstitutionally vague as applied to Carelon. View "Carelon Behavioral Health, Inc. v. State" on Justia Law

Disney Platform Distribution, BAMTech, and Hulu, subsidiaries of the Walt Disney Company, provide video streaming services to subscribers in the City of Santa Barbara. In 2022, the City’s Tax Administrator notified these companies that they had failed to collect and remit video users’ taxes under Ordinance 5471 for the period January 1, 2018, through December 31, 2020, resulting in substantial assessments. The companies appealed to the City Administrator, and a retired Associate Justice served as hearing officer, ultimately upholding the Tax Administrator’s decision.Following the administrative appeal, the companies sought judicial review by filing a petition for a writ of administrative mandate in the Superior Court of Santa Barbara County. The trial court denied their petition, finding that the Ordinance does apply to video streaming services and rejecting arguments that the Ordinance violated the Internet Tax Freedom Act, the First Amendment, and Article XIII C of the California Constitution. The trial court also found there was no violation of Public Utilities Code section 799’s notice requirements, as the City’s actions did not constitute a change in the tax base or adoption of a new tax.On appeal, the California Court of Appeal, Second Appellate District, Division Six, affirmed the trial court’s judgment. The court held that the Ordinance applies to video streaming services, interpreting the term “channel” in its ordinary, non-technical sense and finding that the voters intended technological neutrality. The court further held that the Ordinance does not violate the Internet Tax Freedom Act because video streaming subscriptions and DVD sales/rentals are not “similar” under the Act. Additionally, the court concluded the tax is not a content-based regulation of speech under the First Amendment, and that delayed enforcement did not constitute a tax increase requiring additional voter approval or notice under the California Constitution or Public Utilities Code section 799. View "Disney Platform Distribution v. City of Santa Barbara" on Justia Law

A nonprofit organization that publishes content critical of United States immigration policy was issued a subpoena by the New York Attorney General’s office seeking documents related to its governance, finances, and relationships with vendors and contractors. The organization alleged that the subpoena was motivated by a desire to suppress its viewpoints and thus violated its rights under the First Amendment and the New York State Constitution. The Attorney General, however, maintained that the investigation was prompted by concerns about possible self-dealing and regulatory noncompliance.After the subpoena was issued, the nonprofit partially responded but maintained objections. It then filed a federal lawsuit seeking damages and an injunction against enforcement of the subpoena, claiming the subpoena was retaliatory and unconstitutional. Shortly thereafter, the Attorney General initiated a special proceeding in New York State Supreme Court to compel compliance. The organization moved to dismiss or stay the state proceeding, raising constitutional arguments. The state court ruled against the nonprofit, ordering compliance with the subpoena (with some redactions allowed), and the New York Appellate Division, First Department affirmed. The New York Court of Appeals dismissed a further appeal.The United States District Court for the Northern District of New York denied the nonprofit’s request for a preliminary injunction and dismissed the federal claims, holding that they were precluded by the earlier state court judgment under the doctrine of res judicata. The United States Court of Appeals for the Second Circuit affirmed the district court’s judgment, holding that the state court’s decision was final and on the merits, involved the same parties and subject matter, and therefore barred the federal claims. The court also dismissed as moot the appeal of the denial of preliminary injunctive relief. View "VDARE Foundation, Inc. v. James" on Justia Law

David S. Brimer, a disabled veteran with preference eligibility, was employed as a GS-13 Supervisory Human Resources Specialist for the Naval Bureau of Medicine and Surgery. He applied for a merit promotion to a GS-14 Assistant Human Resources Officer position with the Naval Education and Training Command. Although the position was open to current permanent employees, VEOA eligibles, and DoD Military Spouse Preference eligibles, his application was not initially referred to the hiring official due to an erroneous belief by the agency that he had not met the time-in-grade requirement. After Brimer filed a complaint with the Department of Labor, the agency acknowledged the error but determined, upon review, that Brimer was not among the most highly qualified candidates for the position.Brimer subsequently appealed to the Merit Systems Protection Board, alleging that the agency obstructed his right to compete for employment and violated his veterans’ preference rights under 5 U.S.C. § 3304(f)(1). The administrative judge denied his request for corrective action, stating that the initial error had been remedied through a proper merit review. The Board affirmed, relying on Kerner v. Department of the Interior, 778 F.3d 1336 (Fed. Cir. 2015), and concluded that § 3304(f) does not apply to veterans already employed by the federal government, thus denying Brimer corrective action as a matter of law.The United States Court of Appeals for the Federal Circuit reviewed the Board’s decision. Applying the standard set forth in 5 U.S.C. § 7703(c), the court held that the Board correctly interpreted precedent and the statute, affirming that 5 U.S.C. § 3304(f)(1) does not entitle currently employed federal veterans to corrective action under VEOA for merit promotion vacancies. The Board’s decision denying Brimer's claims was affirmed. View "BRIMER v. NAVY " on Justia Law