Justia Government & Administrative Law Opinion Summaries

A private company operating a federal immigration detention facility in Washington State challenged the enforcement of several provisions of a state law that imposed health, safety, and inspection requirements on private detention centers. The law required the state Department of Health to adopt rules ensuring sanitary and safe conditions, authorized unannounced inspections, provided for civil penalties for violations, and created a private right of action for detainees. The company argued that these provisions violated the doctrine of intergovernmental immunity and were preempted by federal law, claiming they improperly targeted federal contractors and conflicted with federal standards.The United States District Court for the Western District of Washington granted a preliminary injunction, finding that the challenged sections of the law violated intergovernmental immunity by discriminating against the federal government and its contractor. The court compared the requirements imposed on the federal facility to those imposed on state prisons and concluded that the law treated the federal contractor less favorably. The state appealed, and while the appeal was pending, the Washington legislature amended the law, but the changes did not materially alter the issues on appeal.The United States Court of Appeals for the Ninth Circuit vacated the district court’s preliminary injunction and remanded for further proceedings. The Ninth Circuit held that the appropriate comparison for determining discrimination under intergovernmental immunity is between the federal immigration facility and other civil detention facilities in the state, not state prisons. The court directed the district court to make this comparison in the first instance. The Ninth Circuit also held that the challenged provisions were not preempted by federal law and that the district court erred in enjoining the private right of action, as the state officials named as defendants had no enforcement authority under that provision. The case was remanded for further proceedings consistent with these holdings. View "THE GEO GROUP, INC. V. INSLEE" on Justia Law

An Army veteran serving a lengthy prison sentence in Florida applied for and received disability benefits for service-related post-traumatic stress disorder. Initially, the Veterans Benefits Administration approved his claim at a 70 percent rate, later increasing it to 80 percent. However, after his felony conviction and incarceration, the Administration reduced his monthly benefits to a 10 percent rate pursuant to 38 U.S.C. § 5313, which limits disability payments for veterans incarcerated for more than 60 days due to a felony.The veteran filed a pro se complaint in the United States District Court for the Middle District of Florida, naming the United States Congress as defendant. He alleged that the statute reducing his benefits violated the Bill of Attainder Clause and the Equal Protection component of the Fifth Amendment, seeking both prospective and retroactive relief. A magistrate judge recommended dismissal, assuming without deciding that the court had jurisdiction over facial constitutional challenges, but finding the claims frivolous. The district court adopted this recommendation, dismissing the complaint and declining to address the plaintiff’s general objections.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that sovereign immunity barred the suit against Congress, as Congress has not waived immunity for constitutional claims arising from its enactment of legislation. The court further held that any amendment to name a different defendant would be futile because the Veterans’ Judicial Review Act provides an exclusive review scheme for challenges to veterans’ benefits decisions, channeling all such claims—including constitutional challenges—through the administrative process and ultimately to the Court of Appeals for Veterans Claims and the Federal Circuit. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of jurisdiction. View "Johnson v. United States Congress" on Justia Law

Members of the Crow Tribe who own trust allotments on the Crow Reservation challenged the loss of their historic water rights following the ratification of the Crow Tribe-Montana Compact and the Crow Tribe Water Rights Settlement Act. The Settlement Act, passed by Congress in 2010, codified a negotiated agreement among the Crow Tribe, the state of Montana, and the United States, which defined tribal water rights and provided substantial federal funding for water infrastructure. In exchange, the Tribe and allottees agreed to waive all other water rights claims. The Act required the Secretary of the Interior to publish a Statement of Findings certifying that certain conditions were met, which would trigger the waiver of prior water rights.After the Secretary published the Statement of Findings in June 2016—following a deadline extension agreed to by the Tribal Chairman and the Secretary—several allottees filed suit nearly six years later. They argued that the extension was invalid because, under the Crow Constitution, only the Tribal General Council or Legislature could authorize such an agreement. They also alleged that the Secretary’s action exceeded statutory authority, breached trust obligations, and violated their Fifth Amendment rights. The United States District Court for the District of Columbia dismissed the complaint for failure to state a claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the dismissal de novo. The court held that the Secretary’s publication of the Statement of Findings constituted final agency action reviewable under the Administrative Procedure Act, but found the Secretary reasonably relied on the Tribal Chairman’s authority to extend the deadline. The court further held that the Settlement Act created specific trust duties, but the plaintiffs failed to plausibly allege any breach. The court also concluded that the plaintiffs’ Fifth Amendment claims for takings, due process, and equal protection failed as a matter of law. The judgment of the district court was affirmed. View "Hill v. DOI" on Justia Law

A high school in a Pennsylvania school district displayed approximately 70 books in its library, some of which addressed LGBTQ+ issues in anticipation of Pride Month. A third-party contractor photographed the display and posted it on Facebook. Two school board members, David Valesky and Luigi DeFrancesco, shared the post on their personal Facebook accounts, with Valesky adding commentary critical of the display. This sparked public debate, including a newspaper article and discussions at subsequent school board meetings. Thomas Cagle, a local resident, submitted a request under Pennsylvania’s Right-to-Know Law (RTKL) seeking, among other things, all Facebook posts and comments by the two board members related to homosexuality and the school district.The school district partially denied the request, providing some emails but refusing to disclose any social media content, arguing that the posts were on personal accounts and not within the district’s possession. Cagle appealed to the Pennsylvania Office of Open Records (OOR), which ordered disclosure, reasoning that the content, not the ownership of the account, determined whether the posts were public records. The district sought judicial review in the Court of Common Pleas of Crawford County, which agreed with the OOR and ordered disclosure, finding that the posts documented district business and were thus subject to the RTKL.On appeal, the Commonwealth Court vacated the trial court’s order and remanded for further proceedings, instructing the lower court to consider additional factors to determine whether the posts were “of the agency” under the RTKL. The Supreme Court of Pennsylvania reviewed the case and held that the RTKL’s two-part test—whether the information documents a transaction or activity of an agency and was created, received, or retained in connection with agency business—applies to all forms of communication, including social media. The Court affirmed the Commonwealth Court’s order to remand for further fact-finding, clarifying that no special test applies to social media, but relevant facts must be considered in each case. View "Penncrest SD v. Cagle" on Justia Law

Two brothers with developmental disabilities, Gaven and Jared, live with their parents, who are certified to provide in-home care. Both brothers qualified for Maine’s “Single Member Services,” which would allow each to receive one-on-one care from a designated provider. The family requested that each parent be reimbursed for providing care to one brother. However, the Maine Department of Health and Human Services determined that, because the brothers lived together, they were only eligible for “Two Member Services,” meaning a single provider would be reimbursed to care for both, at half the total rate. The parents continued to provide one-on-one care to both brothers, but were only reimbursed for one provider, resulting in a significant financial shortfall.The family challenged this determination in Maine Superior Court, which ruled in their favor, finding that the Department’s interpretation of its rules was arbitrary and inconsistent with its policies. Following this decision, the Department began reimbursing both parents for providing one-on-one care. The family then filed a federal lawsuit seeking damages for the period before the state court’s ruling, alleging discrimination under Title II of the Americans with Disabilities Act (ADA). The United States District Court for the District of Maine dismissed the case, holding that the Department was protected by Eleventh Amendment sovereign immunity.On appeal, the United States Court of Appeals for the First Circuit reversed the district court’s dismissal. The First Circuit held that the Department was not entitled to sovereign immunity because Congress validly abrogated such immunity under Title II of the ADA in this context. The court found that the Department’s policy violated the brothers’ equal protection rights, as there was no rational basis for providing reduced services solely because the brothers lived together. The case was remanded for further proceedings. View "McKenna v. Maine Department of Health and Human Services" on Justia Law

A nonprofit Christian ministry that provides youth programs in Oregon applied for state grant funding from the Oregon Department of Education’s Youth Development Division. The Division had recently added a rule requiring all grant applicants to certify that they do not discriminate based on religion in employment, vendor selection, subcontracting, or service delivery. The ministry, whose mission is to share Christian teachings, requires all employees and volunteers to affirm a Christian Statement of Faith and be involved in a local church. After initially awarding the ministry a conditional grant, the Division withdrew the award upon discovering the ministry’s religious hiring requirements.The United States District Court for the District of Oregon denied the ministry’s request for a preliminary injunction to reinstate the grant and enjoin enforcement of the rule, finding the ministry unlikely to succeed on the merits of its First Amendment claims. The court also dismissed all claims, including those for damages, based on qualified immunity, even though the defendants had only moved to dismiss the damages claims.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The Ninth Circuit held that the rule, as applied to grant-funded initiatives, is likely neutral and generally applicable, thus not violating the Free Exercise Clause, and is a reasonable, viewpoint-neutral condition for participation in the grant program. The court also found that the ministry’s religious autonomy claims were unlikely to succeed, as the relevant doctrines are affirmative defenses, not standalone claims. However, the court held that applying the rule to the ministry’s non-grant-funded initiatives likely imposes an unconstitutional condition on expressive association. The Ninth Circuit directed the district court to enjoin enforcement of the rule as to non-grant-funded initiatives, affirmed the dismissal of damages claims due to qualified immunity, and reversed the dismissal of claims for declaratory and injunctive relief. View "YOUTH 71FIVE MINISTRIES V. WILLIAMS" on Justia Law

Ferdinand E. Marcos, former President of the Philippines, deposited approximately $2 million in a New York Merrill Lynch account in 1972, which grew to over $40 million. These funds, known as the Arelma Assets, were proceeds of Marcos’s criminal activities. After Marcos’s ouster, multiple parties—including the Republic of the Philippines, a class of nearly 10,000 human rights victims, and the estate of Roger Roxas (from whom Marcos had stolen treasure)—asserted competing claims to these assets. The Republic obtained a forfeiture judgment from a Philippine court and requested the U.S. Attorney General to enforce it under 28 U.S.C. § 2467.The United States District Court for the Southern District of New York reviewed the enforcement application. The court rejected the class’s affirmative defenses, which included arguments based on statute of limitations, subject matter jurisdiction, lack of notice, and fraud. The court also found that Roxas lacked Article III standing because she failed to show a sufficient interest in the Arelma Assets, and denied her leave to amend her answer. The court entered judgment for the Government, allowing the assets to be returned to the Republic of the Philippines.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the class failed to create a genuine dispute of material fact as to any of its affirmative defenses and that Roxas lacked standing to participate as a respondent. The court also upheld the denial of intervention by Golden Budha Corporation, finding its interests adequately represented and lacking standing. The main holding is that the Government’s application to enforce the Philippine forfeiture judgment was timely and proper, and that neither the class nor Roxas could block enforcement or claim the assets. View "In re: Enforcement of Philippine Forfeiture Judgment" on Justia Law

The case concerns a series of actions taken by the leadership of the Consumer Financial Protection Bureau (CFPB) in early 2025, following a change in presidential administration. The new Acting Directors, first Scott Bessent and then Russell Vought, implemented measures to significantly downsize the agency. These included pausing most agency activities, terminating employees (including the Student Loan Ombudsman), canceling contracts, declining additional funding, moving to smaller headquarters, and requiring advance approval for agency work. Some statutorily required services were neglected during this period, though agency leadership later clarified that legally mandated work should continue.Several plaintiffs, including organizations representing CFPB employees and groups that use CFPB services, filed suit in the United States District Court for the District of Columbia. They alleged that the agency’s actions amounted to an unlawful attempt to “shut down” the CFPB, violating both statutory mandates and the separation of powers. The district court found that agency leadership had indeed decided to shut down the Bureau and issued a preliminary injunction. This injunction required the government to reinstate terminated employees, refrain from further firings except for cause, maintain certain services, and rescind contract terminations, among other measures.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the district court lacked jurisdiction over claims related to loss of employment, as such claims must proceed through the Civil Service Reform Act’s specialized review scheme. For the remaining plaintiffs, the court found that their claims did not challenge a final agency action reviewable under the Administrative Procedure Act (APA), nor did they present a constitutional claim reviewable in equity. The court concluded that the plaintiffs’ attempt to challenge an inferred, overarching decision to shut down the CFPB was not viable under the APA or in equity. Accordingly, the D.C. Circuit vacated the preliminary injunction and remanded the case. View "National Treasury Employees Union v. Vought" on Justia Law

A pharmaceutical company sought approval from the Food and Drug Administration (FDA) to market tasimelteon, a drug previously approved for a rare sleep disorder, as a treatment for jet lag. The company submitted results from several clinical trials, focusing on both objective sleep measures and subjective assessments of alertness and next-day functioning. The FDA’s Center for Drug Evaluation and Research issued a complete response letter indicating that the application did not provide substantial evidence of efficacy, particularly criticizing the measurement of next-day impairment and the tools used for subjective endpoints. The company engaged in further discussions and dispute resolution with the FDA, including proposing a narrower indication for approval, but these efforts were unsuccessful.After the FDA issued a formal notice of opportunity for a hearing (NOOH), the company requested a hearing and submitted expert declarations supporting the adequacy of its clinical evidence. The FDA ultimately denied both the application and the hearing request, finding no genuine and substantial issue of fact warranting a hearing. The company then petitioned the United States Court of Appeals for the District of Columbia Circuit for review, arguing that the FDA was required to hold a hearing, that material factual disputes existed, that the FDA’s decision-making was arbitrary and capricious, and that the final decision violated the Appointments Clause.The United States Court of Appeals for the District of Columbia Circuit held that the Food, Drug, and Cosmetic Act does not require the FDA to hold a hearing before denying every new drug application, but the agency must grant a hearing if there are material factual disputes. The court found that, in this case, the FDA’s refusal to hold a hearing was arbitrary and capricious because the company’s expert evidence created genuine disputes over the adequacy of the clinical trials. The court remanded the case to the FDA for further proceedings consistent with its opinion. View "Vanda Pharmaceuticals, Inc. v. FDA" on Justia Law

A state port authority and a group of related companies entered into a series of letters of intent (LOIs) regarding the possible expansion and operation of a port facility. The final LOI, signed in December 2019, included provisions for confidentiality, exclusivity, and certain legally binding terms, but also stated that it was not a binding agreement to consummate the potential transaction. The port authority’s board approved the LOI and several subsequent extensions, but the board minutes did not include the terms or conditions of the LOI. After negotiations failed, the port authority terminated the LOI. The companies claimed significant losses and alleged the port authority had breached the LOI and misused confidential information.The Harrison County Circuit Court found that the LOI was unenforceable under Mississippi’s “minutes rule,” which requires that public board contracts be sufficiently detailed in the board’s official minutes. The court dismissed all claims based on the LOI, including breach of contract and quantum meruit, but allowed claims for unjust enrichment and misappropriation of trade secrets to proceed. Both parties sought interlocutory appeal, and the appeals were consolidated.The Supreme Court of Mississippi affirmed the lower court’s ruling that the LOI was unenforceable because the board minutes did not contain enough terms to determine the parties’ obligations, and held that the minutes rule was not superseded by the Open Meetings Act. The court also held that unjust enrichment, as an implied contract claim, was barred by the minutes rule and reversed the trial court’s denial of summary judgment on that claim. However, the court affirmed that the companies’ notice of claim regarding misappropriation of trade secrets was sufficient under the Mississippi Tort Claims Act. The case was remanded for further proceedings on the remaining claim. View "The Mississippi State Port Authority at Gulfport v. Yilport Holding A.S." on Justia Law