Justia Government & Administrative Law Opinion Summaries

Kevin Lewis, who is legally blind, was arrested in Georgia on an outstanding warrant and detained for less than 48 hours in the Chatham County jail and for about 16 days in the Fulton County jail. During both periods of incarceration, Lewis alleges he was denied assistance with reading documents, navigating the facilities, accessing the grievance process, and obtaining requested medications. He also reports that, despite his requests, he was not provided accommodations for using jail telephones and kiosks.After his release and the dismissal of criminal charges against him, Lewis filed suit in the United States District Court for the Northern District of Georgia against Sheriffs John Wilcher and Patrick Labat in their official capacities, seeking damages and injunctive relief under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the sheriffs. The court found that Lewis had not produced sufficient evidence to show he was denied benefits or discriminated against “by reason of” his disability, and had not shown that the sheriffs engaged in intentional discrimination. Regarding his claims for injunctive relief, the court determined they were moot because Lewis was no longer incarcerated.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that Lewis failed to present evidence of intentional discrimination by the sheriffs, as required for damages under both statutes. It also held that his claims for injunctive relief were moot, as there was no reasonable expectation he would be subject to the challenged conditions again. The district court’s grant of summary judgment was thus affirmed. View "Lewis v. Sheriff, Fulton County Georgia" on Justia Law

The case involves an individual, B.K., who has schizophrenia and has been under a conservatorship pursuant to the Lanterman-Petris-Short (LPS) Act since 2019. The conservatorship was initially established after B.K. was found to be gravely disabled as a result of a mental disorder, and it has been renewed annually following court hearings. In several renewal proceedings, B.K. expressed her desire to contest the conservatorship, at times requesting either a court or jury trial. At the most recent renewal proceeding, B.K. initially requested a jury trial but later, after consulting with her attorney, chose to proceed with a court trial instead. B.K. confirmed this choice in open court.The Superior Court of Los Angeles County conducted the court trial, during which expert testimony and B.K.’s own statements supported a finding that she remained gravely disabled and unable to care for herself due to her mental illness. The court renewed the conservatorship for another year. B.K. appealed, arguing that the trial court failed to adequately advise her of her right to a jury trial or to ensure that her waiver of that right was knowing and intelligent.The California Court of Appeal, Second Appellate District, Division Four, reviewed the case. Applying de novo review to statutory claims and substantial evidence review to the trial court’s implied finding, the Court of Appeal concluded that B.K. was aware of her right to a jury trial and that, under the totality of the circumstances, her waiver—made through counsel and confirmed in court—was knowing and intelligent. The appellate court held that direct advisement or a personal waiver was not required under the LPS Act when counsel confers with the conservatee and there is no indication of lack of authority or client understanding. The court affirmed the ruling, finding no reversible error. View "Conservatorship of B.K." on Justia Law

In 2005, an individual was convicted of endangering the welfare of a child and placed on Parole Supervision for Life (PSL) in New Jersey. The State Parole Board imposed two special conditions: a ban on accessing social media and a ban on viewing or possessing pornography. In 2018, the individual was arrested on a parole warrant for allegedly violating both conditions. After a hearing, the Parole Board found violations, revoked PSL, and ordered twelve months of incarceration. The individual challenged the constitutionality of the conditions, arguing they violated First Amendment rights. While an appeal was pending, the Parole Board vacated the revocation in February 2020 and later discharged the conditions. On June 1, 2020, the Board issued a decision stating there was no clear and convincing evidence of violations.The complainant and spouse then filed suit under the New Jersey Civil Rights Act (CRA) and the Tort Claims Act (TCA) against the State and others, alleging substantive due process violations, gross negligence, deliberate indifference, and false arrest/imprisonment. The trial court dismissed all claims as time-barred, holding that the statute of limitations began to run at various points before June 2020. The Appellate Division affirmed, finding that the claims accrued earlier and that even under the favorable-termination rule from Heck v. Humphrey, the relevant accrual event was the Board's February 2020 vacatur of the revocation.The Supreme Court of New Jersey held that the favorable-termination rule from Heck v. Humphrey applies to claims under the CRA and the TCA, meaning that civil rights claims that necessarily challenge the validity of a criminal or quasi-criminal proceeding do not accrue until that proceeding is terminated in the plaintiff’s favor. The Court determined that substantive due process and related claims accrued on June 1, 2020, making them timely, but that any false arrest/imprisonment claim accrued earlier and was time-barred. The Court reversed the dismissal of the first three counts and affirmed the dismissal of the false arrest/imprisonment claim. View "C.A.L. v. State of New Jersey" on Justia Law

After the Missouri General Assembly enacted Senate Bill No. 22 (SB 22) in 2025, which made several changes to statutes governing ballot summaries and judicial proceedings, a Missouri resident and taxpayer challenged its constitutionality. SB 22 as introduced focused solely on amending the process for judicial review of ballot summary statements. During the legislative process, SB 22 was amended to include provisions expanding the attorney general’s authority to appeal certain preliminary injunctions, a subject unrelated to ballot summaries, and the bill’s title was changed from “relating to ballot summaries” to “relating to judicial proceedings.” After passage by both legislative chambers and the Governor’s signature, the bill became law.The Circuit Court of Cole County reviewed the case after the plaintiff alleged SB 22 violated the Missouri Constitution’s original purpose, single subject, and clear title requirements, as well as equal protection guarantees. The circuit court found the bill did not violate the procedural constitutional provisions, but it did find that the amendment to section 526.010 (concerning the attorney general’s appellate rights) violated equal protection and was severable from the rest of the bill. The court allowed the remaining portions, primarily those addressing ballot summaries, to stand. The plaintiff appealed, challenging the findings on the procedural requirements, while the State cross-appealed on standing and equal protection.The Supreme Court of Missouri heard the case and held that the plaintiff had taxpayer standing because SB 22’s provisions resulted in a direct expenditure of public funds. Upon de novo review, the Supreme Court found that SB 22 violated the original purpose requirement of article III, section 21 of the Missouri Constitution because the added provision regarding the attorney general’s appellate rights was not germane to the bill’s original purpose. The Court further held that the offending provision could not be severed, and therefore invalidated SB 22 in its entirety, reversing the judgment of the circuit court. View "Nicholson v. State" on Justia Law

Ten nonprofit organizations that received federal grants through the U.S. Citizenship and Immigration Services’ “Citizenship and Integration Grant Program” filed suit after the Department of Homeland Security (DHS) froze and subsequently terminated their grant funding. The freeze and termination followed an executive order issued by the incoming President in January 2025 directing DHS to pause and review grants that funded services to undocumented immigrants, with the aim of ensuring compliance with law and preventing waste, fraud, or abuse. DHS notified grantees of the freeze in February 2025 and terminated the grants in March 2025, prompting the plaintiffs to seek a preliminary injunction to restore the program and funding.The United States District Court for the District of Maryland denied the plaintiffs’ motion for a preliminary injunction. The court determined that the plaintiffs’ claims were essentially contractual—seeking disbursement of funds based on grant agreements—and thus fell under the exclusive jurisdiction of the United States Court of Federal Claims pursuant to the Tucker Act. The court also found that the plaintiffs had not identified a reviewable “final agency action” under the Administrative Procedure Act (APA). Additionally, it concluded that the plaintiffs had failed to provide adequate legal authority for their ultra vires and separation-of-powers claims.Reviewing the appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the relief sought by the plaintiffs was materially indistinguishable from relief denied in recent Supreme Court cases, Department of Education v. California and National Institutes of Health v. Public Health Association. It concluded that claims seeking to enforce contractual obligations to pay money must be brought in the Court of Federal Claims and that the plaintiffs had not shown a likelihood of success on their alternative constitutional or statutory claims. The district court’s denial of the preliminary injunction was therefore affirmed. View "Solutions in Hometown Connections v. Noem" on Justia Law

The case centers on the Trans Alaska Pipeline System (TAPS), which transports crude oil from Alaska’s North Slope, with oil from different shippers being commingled in the pipeline. To address variations in oil quality, a “Quality Bank” compensates shippers who inject higher-quality oil and charges those with lower-quality oil. The valuation of one particular oil component, Resid—the heaviest and least valuable cut—has been disputed for decades. Petro Star, a shipper whose refineries lack specialized units to further process Resid, argued that Resid was undervalued, while ConocoPhillips contended it was overvalued. The TAPS owners, who administer the Quality Bank, also challenged a Federal Energy Regulatory Commission (FERC) finding that the Bank’s administrator violated tariff provisions.Following a 2013 FERC investigation into the Resid valuation formula, both Petro Star and ConocoPhillips intervened, seeking changes. After initial FERC findings were remanded for further explanation by the United States Court of Appeals for the District of Columbia Circuit, FERC held additional hearings. An administrative law judge (ALJ) concluded the formula was just and reasonable, and FERC largely affirmed this result, also finding a tariff violation by the Quality Bank administrator for failing to update formula yields based on monthly Resid testing.On review, the United States Court of Appeals for the District of Columbia Circuit held that FERC’s formula for valuing Resid remains just and reasonable, as neither Petro Star nor ConocoPhillips demonstrated the formula to be unjust or unreasonable. The court also upheld FERC’s finding that the Quality Bank administrator violated the tariff by not updating formula yields with each test, but found FERC’s prospective remedy—requiring monthly testing and annual yield updates—was appropriate. The court denied all three petitions. View "Petro Star Inc. v. FERC" on Justia Law

A family that inherited a renowned art collection in Hungary prior to World War II sought to recover dozens of valuable artworks seized by the Hungarian government and its Nazi collaborators during the Holocaust. The heirs, who became citizens of the United States and other countries, alleged that the majority of the collection was confiscated during the Nazi occupation and dispersed across Europe and later deposited at Hungarian institutions. Some pieces were returned to the family after the war, only to be retaken by the government under various circumstances, including criminal forfeiture and postwar policies.The heirs initially pursued their claims in Hungarian courts without success. In 2010, they sued the Republic of Hungary and several Hungarian museums in the United States District Court for the District of Columbia, invoking the Foreign Sovereign Immunities Act (FSIA) expropriation and commercial activity exceptions. The district court partly dismissed the claims on international comity grounds but retained jurisdiction over most artworks. The U.S. Court of Appeals for the District of Columbia Circuit reversed the comity dismissal and affirmed jurisdiction on different grounds. Subsequent rulings narrowed the scope of claims, particularly after the Supreme Court’s decision in Federal Republic of Germany v. Philipp, which clarified the FSIA’s expropriation exception and incorporated the domestic-takings rule, limiting jurisdiction over property taken from a sovereign’s own nationals.On appeal, the United States Court of Appeals for the District of Columbia Circuit concluded that U.S. courts lack jurisdiction over the family’s claims. The court held that plaintiffs failed to establish that the seizure of their artwork violated the international law of expropriation, as required by the FSIA. It found no international authority supporting jurisdiction for wartime or stateless-person takings, and that treaties and the domestic-takings rule further barred the claims. The court affirmed the district court’s complete dismissal of the litigation. View "De Csepel v. Republic of Hungary" on Justia Law

A company sought approval from the Illinois Commerce Commission (ICC) to construct and operate a high-voltage transmission line for renewable energy, running from Kansas through parts of Illinois to Indiana. The applicant, a special purpose entity owned by Invenergy, did not have existing utility assets in Illinois and planned to use a common energy industry “project finance” model—securing long-term contracts and commercial agreements after regulatory approval to finance construction through a combination of debt and equity. The applicant presented testimony regarding its management’s extensive experience with large-scale energy projects and relationships with major lenders, but did not submit traditional financial statements.The ICC reviewed the application, accepted evidence about the applicant’s financing strategy and experience, and imposed a condition that required the applicant to secure full financing for the entire project before beginning any construction on Illinois easement property. The ICC found that the applicant satisfied the statutory requirement to be “capable of financing the proposed construction without significant adverse financial consequences” for the utility or its customers, and issued the certificate of public convenience and necessity (CPCN).On direct administrative review, the Appellate Court of Illinois, Fifth District, reversed the ICC’s grant of the CPCN. The appellate court concluded that the applicant failed to show it could currently finance the project at the time of the certificate’s issuance, and characterized the project finance method as speculative. It held that section 8-406.1(f)(3) of the Public Utilities Act required proof of present financing capability as a condition precedent to granting a CPCN.The Supreme Court of Illinois reversed the appellate court’s judgment and affirmed the ICC’s decision. The court held that section 8-406.1(f)(3) does not require an applicant to prove current, present financing capability at the time of certificate issuance. Instead, it requires a showing of capacity to finance without significant adverse financial consequences, which may be established by substantial evidence of future financing ability and industry practices. The case was remanded to the appellate court for further proceedings on unaddressed issues. View "Concerned Citizens & Property Owners v. Illinois Commerce Comm'n" on Justia Law

Jackson County Heart ASC, LLC submitted an application to the Mississippi State Department of Health (MSDH) seeking a certificate of need (CON) to establish a joint venture cardiac ambulatory surgical facility (JV-CASF) in Gautier, Mississippi. The proposed facility would provide outpatient cardiac catheterization services and was to be jointly owned by an acute care hospital and licensed cardiologists, as defined by the Mississippi State Health Plan. The application included supporting affidavits from cardiologists and financial projections, indicating that this would be the only freestanding outpatient JV-CASF in the Gulf Coast service area.MSDH staff recommended approval of the application, finding substantial compliance with relevant criteria. Following Singing River Health System’s request for a hearing, a hearing officer considered testimony and evidence from both sides, including expert witnesses and financial analyses. Although one supporting physician withdrew his endorsement at the hearing, the hearing officer ultimately recommended approval based on the entirety of the evidence. MSDH’s state health officer adopted these findings and issued a final order approving the CON. Singing River appealed to the Hinds County Chancery Court, which affirmed the approval after oral argument. Singing River then appealed to the Supreme Court of Mississippi.On appeal, the Supreme Court of Mississippi reviewed arguments regarding the adequacy of the application, economic viability, and potential adverse impacts on Singing River’s services and charitable care. Applying a highly deferential standard, the Court found substantial evidence supporting MSDH’s decision. The Court held that the application met the requirements of the State Health Plan and CON Review Manual, satisfied economic viability, and would not have a significant adverse impact on Singing River or its ability to provide charitable care. The Supreme Court affirmed MSDH’s approval of the CON. View "Singing River Health System v. Mississippi State Department of Health" on Justia Law

A federal employee working at a Veterans Affairs healthcare facility discovered that a nurse practitioner was improperly receiving overtime pay that was not actually earned and not related to COVID, contrary to requirements. The employee’s supervisors allegedly created and signed a false waiver to justify these payments, resulting in significant unearned compensation. When the employee refused to participate in the scheme and reported the conduct to the VA Office of Inspector General, he claimed to have been subjected to workplace retaliation, including a reprimand and demotion.The employee filed suit in the United States District Court for the District of Maine, asserting a qui tam false claims action against his supervisors and a retaliation claim under the False Claims Act (FCA) against the Secretary of the Department of Veterans Affairs, in his official capacity. The government intervened and successfully moved to dismiss the false claims and conspiracy counts against the supervisors. The government also sought dismissal of the retaliation claim, arguing that the employee’s exclusive remedies lay under the Whistleblower Protection Act (WPA), not the FCA. The district court, however, dismissed the retaliation claim on the ground that the FCA does not contain an express waiver of the federal government’s sovereign immunity for such claims, and thus federal courts lack subject-matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that Congress has not expressly waived the federal government’s sovereign immunity to permit retaliation suits against federal employers under Section 3730(h) of the FCA. The court found that neither the FCA’s text nor its structure provided the required clear waiver of sovereign immunity, distinguishing such waivers present in other statutes. Accordingly, the First Circuit affirmed the district court’s dismissal for lack of subject-matter jurisdiction. View "US ex rel. Sargent v. Collins" on Justia Law