Justia Government & Administrative Law Opinion Summaries

Rhode Island Truck Center, LLC (RITC) filed a protest against Daimler Trucks North America, LLC (DTNA) for allegedly violating Rhode Island General Laws § 31-5.1-4.2(a). DTNA had granted a franchise to Advantage Truck Raynham, LLC (ATG Raynham) in Raynham, Massachusetts, which RITC claimed was within its "relevant market area" as defined in their franchise agreement. RITC argued that DTNA failed to provide the required statutory notice before establishing the new dealership.The Dealers' Hearing Board determined it lacked jurisdiction over RITC's protest, citing the dormant Commerce Clause of the United States Constitution. RITC then filed an administrative appeal in the Superior Court, which DTNA removed to the United States District Court for the District of Rhode Island. The District Court concluded that the Dealer Law could not be applied extraterritorially without violating the Commerce Clause. The United States Court of Appeals for the First Circuit certified a question to the Rhode Island Supreme Court to determine whether a "relevant market area" under § 31-5.1-4.2(a) could extend beyond Rhode Island's borders.The Rhode Island Supreme Court reviewed the certified question de novo and concluded that the statute's plain language and legislative intent allowed a "relevant market area" to extend beyond state borders. The Court noted that the statute's definition of "relevant market area" includes a 20-mile radius or the area defined in the franchise agreement, whichever is greater, without limiting it to within Rhode Island. The Court emphasized that the legislature's intent was to provide dealers with a protective area that could extend beyond state lines, especially given Rhode Island's small geographic size. Thus, the Court answered the certified question in the affirmative, allowing the "relevant market area" to extend beyond Rhode Island's borders. View "Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC" on Justia Law

Nikko Cerrone, a sixteen-year-old, received the Gardasil HPV vaccine, Flumist influenza vaccine, and Hepatitis A vaccine on October 7, 2015. He later reported decreased stamina and blood in his stools, leading to a diagnosis of ulcerative colitis (UC) in March 2016. He received a second HPV vaccine dose in February 2016 and a third in June 2016, with no documented reaction to the third dose.Cerrone filed a petition for compensation under the National Vaccine Injury Compensation Program, claiming the vaccines caused his UC. The Chief Special Master of the National Vaccine Injury Compensation Program denied his claim, finding that Cerrone failed to prove causation by a preponderance of the evidence. The Court of Federal Claims upheld this decision.The United States Court of Appeals for the Federal Circuit reviewed the case. The court affirmed the lower court's decision, agreeing that Cerrone did not meet the burden of proof required under the Vaccine Act. The court found that the special master correctly applied the legal standards and that the findings were not arbitrary or capricious. The court noted that the special master found the respondent's experts more credible and persuasive than Cerrone's experts. The court also upheld the special master's conclusion that the evidence did not support a proximate temporal relationship between the vaccinations and the onset of UC. The decision of the Court of Federal Claims was affirmed. View "CERRONE v. HHS " on Justia Law

The Institute for Free Speech (IFS), a nonprofit organization that provides pro bono legal services for First Amendment litigation, sought to represent a Texas politician and a political committee in challenging a Texas election law. This law requires political advertising signs to include a government-prescribed notice. IFS refrained from entering into representation agreements due to fear of prosecution under the Texas Election Code, which prohibits corporations from making political contributions, including in-kind contributions such as pro bono legal services.The United States District Court for the Western District of Texas dismissed IFS's complaint for lack of Article III standing, concluding that IFS's claims were not ripe and that qualified immunity barred the individual-capacity claims. The district court assumed IFS had standing but found that the claims were not ripe because the prospective clients did not yet qualify as a candidate and a political committee. The court also concluded that sovereign immunity did not bar the official-capacity claims.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that IFS had standing to pursue its claims. The court found that IFS had demonstrated a serious intent to engage in constitutionally protected conduct, that its proposed conduct would violate Texas law, and that there was a substantial threat of enforcement. The court also concluded that IFS's claims were ripe for adjudication, as the prospective clients qualified as a candidate and a political committee under Texas law.The Fifth Circuit held that the district court erred in dismissing the case for lack of standing and ripeness. However, the court affirmed the dismissal of the individual-capacity claims based on qualified immunity, as the right to provide pro bono legal services in this context was not clearly established. The court also affirmed that the Ex parte Young exception to sovereign immunity applied, allowing the official-capacity claims to proceed. The case was remanded for further proceedings consistent with the opinion. View "Institute for Free Speech v. Johnson" on Justia Law

GreenPower Motor Company Inc. (GreenPower) and San Joaquin Valley Equipment Leasing, Inc. (San Joaquin Leasing) were involved in the California Hybrid and Zero-Emissions Truck and Bus Voucher Incentive Project (HVIP), which subsidizes the price of qualifying electric vehicles (EVs). GreenPower's participation in the HVIP program was suspended following an investigation by the California Air Resources Board (CARB) into their compliance with HVIP requirements. Subsequently, the Attorney General's Office began investigating potential violations of the HVIP program and issued subpoenas to GreenPower and San Joaquin Leasing for documents related to their compliance with HVIP.GreenPower and San Joaquin Leasing filed a petition for writ of mandate in Sacramento County Superior Court to compel CARB to issue vouchers for their EVs. Meanwhile, the Attorney General issued subpoenas as part of a separate investigation. When GreenPower and San Joaquin Leasing did not comply, the Attorney General filed a petition in the City and County of San Francisco Superior Court to enforce the subpoenas. The trial court ordered GreenPower and San Joaquin Leasing to show cause for their non-compliance and eventually required them to produce the requested documents.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court held that the trial court had jurisdiction to enforce the subpoenas and that the doctrine of exclusive concurrent jurisdiction did not apply because the issues in the Sacramento action and the present proceeding were factually and legally distinct. The court also found that the subpoenas were valid, specific, and relevant to the Attorney General's investigation into potential violations of the HVIP program and the California False Claims Act. The order requiring compliance with the subpoenas was affirmed. View "People ex rel. Bonta v. Greenpower Motor Co." on Justia Law

In 2016, California voters approved Proposition 57, which amended the California Constitution to allow the Department of Corrections and Rehabilitation (the department) to award credits for good behavior and rehabilitative or educational achievements. The department adopted regulations to award credits beyond statutory limits and to use credits to advance indeterminately-sentenced inmates’ minimum eligible parole dates. The Criminal Justice Legal Foundation and several family members of crime victims challenged these regulations through a petition for writ of mandate.The Superior Court of Sacramento County denied the writ in part and granted it in part, invalidating the department’s regulations to the extent they allowed the use of credits to advance an indeterminately-sentenced inmate’s minimum eligible parole date. Both the department and the petitioners appealed the decision.The California Court of Appeal, Third Appellate District, reviewed the case. The court held that Proposition 57 properly removed statutory restraints on the department’s authority to award credits, allowing the regulations to supersede contrary statutes. However, the court also held that the department may use credits to advance indeterminately-sentenced inmates’ minimum eligible parole dates only if permitted by existing law, as Proposition 57 is silent on this issue. The court remanded the matter to the trial court with directions to modify the writ of mandate and enter a modified judgment. View "Criminal Justice Legal Foundation v. Department of Corrections and Rehabilitation" on Justia Law

Charley Johnson, trustee of the Charley E. Johnson Revocable Living Trust, purchased approximately 21 acres of land bordering the Tonto National Forest in Gila County, Arizona. Johnson later discovered that many of the improvements on the land, including a house, barn, well, and corrals, were actually on National Forest Service (NFS) land due to an erroneous survey. To resolve this, Johnson filed an application under the Small Tracts Act (STA) to purchase the encroached land. The U.S. Forest Service eventually sold Johnson a 0.59-acre parcel that included the house, barn, and well but excluded the corrals, claiming they were authorized range improvements owned by the United States.The United States District Court for the District of Arizona granted summary judgment in favor of the United States, holding that the Forest Service's decision to exclude the corrals was not subject to judicial review under the Administrative Procedure Act (APA) because it was committed to agency discretion by law. The court also found that the Forest Service's reliance on an appraisal valuing the 0.59-acre parcel at $27,000 was not arbitrary or capricious.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The Ninth Circuit held that the APA's narrow exception for actions committed to agency discretion did not apply to discretionary conveyances under the STA. The court found that the STA and its regulations provide meaningful standards for evaluating the Forest Service's decisions, making them subject to judicial review. The Ninth Circuit remanded the case to the district court to determine whether the Forest Service's decision to exclude the corrals from the STA sale was arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law. View "JOHNSON V. USA" on Justia Law

Jilin Forest Industry Jinqiao Flooring Group Co. ("Jilin") is an exporter of multilayered wood flooring in China. In November 2010, the Department of Commerce ("Commerce") initiated an antidumping investigation into the sale of this product from China, treating China as a non-market economy ("NME") country. Commerce applied a presumption that all companies in an NME country are subject to government control and should be assessed a single antidumping duty rate unless they can demonstrate independence. Jilin successfully demonstrated independence and received a separate rate of 3.31 percent.In the fifth administrative review initiated in February 2017, Commerce selected Jilin as a mandatory respondent. Despite Jilin's cooperation, Commerce found that Jilin failed to rebut the presumption of government control and assigned it the PRC-wide antidumping duty rate of 25.62 percent. Jilin challenged this decision at the Court of International Trade ("CIT"), which questioned the lawfulness of Commerce's NME policy and ordered Commerce to calculate an individual rate for Jilin. On remand, Commerce calculated a zero percent rate for Jilin under protest, and the CIT entered that rate in its final judgment.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that Commerce's practice of applying the NME presumption and assigning a single NME-wide rate to exporters that fail to rebut the presumption is lawful. The court cited binding precedents, including Sigma Corp. v. United States and China Manufacturers Alliance, LLC v. United States, which upheld Commerce's authority to use the NME presumption and assign a single rate to the NME-wide entity. The court reversed the CIT's decision, reinstating the PRC-wide antidumping duty rate of 25.62 percent for Jilin. View "JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US " on Justia Law

M.R., an inmate serving a prison sentence for racketeering, experienced significant health issues, including balance problems and difficulty writing. In August 2020, he was diagnosed with a malignant brain tumor and underwent surgery in January 2021. By November 2022, M.R. was wheelchair-bound with residual neurological deficits. In February 2023, M.R. applied for compassionate release under the Compassionate Release Act (CRA). The New Jersey Department of Corrections (DOC) designated two physicians to review his medical records, who provided conflicting diagnoses regarding his terminal condition status. The DOC ultimately denied M.R. a Certificate of Eligibility for compassionate release.M.R. appealed the DOC's decision, and in August 2023, the Appellate Division remanded the case for reevaluation due to the conflicting medical opinions. The physicians provided updated reports, now uniformly concluding that M.R. did not suffer from a terminal condition or permanent physical incapacity, again relying solely on M.R.'s electronic medical records. The DOC reaffirmed its denial of the Certificate of Eligibility. The Appellate Division later affirmed the DOC's decision, concluding that the CRA does not require physical examinations and that the denial was not arbitrary, capricious, or unreasonable.The Supreme Court of New Jersey reviewed the case, focusing on whether the CRA and its implementing regulation require physical examinations for compassionate release applications. The Court held that the CRA does not mandate physical examinations for medical diagnoses. However, the Court found the DOC's decision to deny M.R. a Certificate of Eligibility in August 2023 to be arbitrary, capricious, and unreasonable. The Court emphasized the need for contemporaneous and comprehensive medical evaluations to support such decisions and reversed the Appellate Division's judgment. View "M.R. v. New Jersey Department of Corrections" on Justia Law

The case involves a challenge to the U.S. Securities and Exchange Commission's (SEC) 2023 Funding Order, which amended the funding structure for the Consolidated Audit Trail (CAT). The CAT was established to create a single electronic system for gathering and maintaining data on stock trades. Initially, the SEC estimated the cost of building and operating the CAT to be significantly lower than the actual costs incurred. The 2023 Funding Order allowed self-regulatory organizations (SROs) to pass all CAT costs to their broker-dealer members, a shift from the original plan that required both SROs and broker-dealers to share the costs.The American Securities Association and Citadel Securities, LLC challenged the 2023 Funding Order, arguing that it was arbitrary and capricious. They contended that the SEC failed to justify the decision to allow SROs to pass all CAT costs to broker-dealers and did not update its economic analysis to reflect the actual costs of the CAT, which had significantly increased since the original estimates.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the SEC's 2023 Funding Order was internally inconsistent and represented an unexplained policy change from previous rules that required both SROs and broker-dealers to share CAT costs. The court also determined that the SEC failed to consider the effects of allowing SROs to pass all CAT costs to broker-dealers, creating a potential free-rider problem. Additionally, the court held that the SEC's reliance on outdated economic analysis was unreasonable given the significant increase in CAT costs.The Eleventh Circuit vacated the 2023 Funding Order, stayed its decision for sixty days to allow the SEC to address the issues, and remanded the matter to the SEC for further proceedings consistent with the court's opinion. View "American Securities Association v. Securities and Exchange Commission" on Justia Law

Mayo Clinic, a Minnesota nonprofit corporation and tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code, sought a refund of unrelated business income tax (UBIT) imposed by the IRS for tax years 2003, 2005-2007, and 2010-2012. The IRS assessed Mayo $11,501,621 in unpaid UBIT, concluding that Mayo was not a qualified educational organization under IRC § 170(b)(1)(A)(ii) because its primary function was not the presentation of formal instruction, and its noneducational activities were not merely incidental to its educational activities. Mayo paid the assessed amount and filed a refund action.The United States District Court for the District of Minnesota granted Mayo summary judgment, holding that Mayo is an educational organization as defined in § 170(b)(1)(A)(ii) and invalidating Treasury Regulation § 1.170A-9(c)(1) for adding requirements not present in the statute. The United States appealed, and the Eighth Circuit reversed the invalidation of the regulation and remanded for further proceedings. On remand, the district court concluded that Mayo had a substantial educational purpose and no substantial noneducational purpose, granting Mayo judgment for the full refund amount plus interest.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that "primary" in this context means "substantial" and that Mayo's substantial patient care activities are not noneducational due to the integration of education and clinical practice. The court concluded that Mayo qualifies as an educational organization under § 170(b)(1)(A)(ii) and that its patient care function does not disqualify it from this status. The judgment of the district court was affirmed. View "Mayo Clinic v. United States" on Justia Law