Justia Government & Administrative Law Opinion Summaries

A man named Donald Prater, Jr. was found partially nude and behaving erratically after leaving a hospital, having previously told a deputy he had used methamphetamine and was hallucinating. Law enforcement officers from the City of Paintsville and Johnson County, along with emergency medical personnel, responded to reports of his behavior. When officers attempted to arrest Prater on a public street, he resisted and force was used, including a taser, pepper spray, and baton strikes. After being handcuffed, Prater stopped breathing and, despite immediate lifesaving efforts, died. The medical examiner found no lethal trauma and attributed the death to excited delirium syndrome, with other health factors possibly contributing.The personal representative of Prater’s estate filed a wrongful death suit in Johnson Circuit Court against various city and county entities and their employees, alleging excessive force, negligence, and wrongful death. The circuit court granted summary judgment to all defendants, finding the officers and emergency personnel were entitled to qualified official immunity, that the force used was reasonable, and that there was no evidence their actions caused Prater’s death. The court also dismissed claims against the city and county entities, including those for negligent hiring and supervision, on the basis that no underlying tort had been established.On appeal, the Kentucky Court of Appeals affirmed in part and reversed in part, holding that some claims against the city and police department for negligent hiring and supervision could proceed, and that the officers’ entitlement to qualified immunity required further factual findings. The Supreme Court of Kentucky reviewed the case and held that all defendants were properly dismissed. The Court concluded that the officers’ actions were discretionary, performed in good faith, and within the scope of their authority, entitling them to qualified official immunity. The Court reversed the Court of Appeals in part, affirmed in part, and remanded for any necessary proceedings. View "CITY OF PAINTSVILLE V. HANEY" on Justia Law

A healthcare provider participated in Kentucky’s Medicaid program, offering in-home services to recipients in rural areas under the Home and Community Based (HCB) Waiver program. The Department for Medicaid Services had, for several years, reimbursed the provider at enhanced rates for “case management” services, even though the relevant administrative regulation did not list “case management” as a reimbursable “revenue code service.” In 2016, the Department determined that these payments were made in error and sought to recoup over $1 million from the provider for services rendered between 2011 and 2013.After the Department initiated recoupment, the provider contested the action through the Cabinet’s administrative process, arguing that the omission of “case management” from the regulation was a drafting error and that the Department should be estopped from recouping the funds due to its prior representations and delay. The administrative hearing officer rejected these arguments, finding the regulation’s text unambiguous and concluding that neither equitable estoppel nor laches applied. The Secretary of the Cabinet adopted this decision. The provider then sought judicial review in the Franklin Circuit Court, which affirmed the agency’s decision. The Kentucky Court of Appeals also affirmed.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals. The Court held that the Department’s regulation unambiguously excluded “case management” from the list of services eligible for enhanced reimbursement, and the Department was within its authority to recoup the overpaid funds. The Court declined to read omitted language into the regulation, found no basis for equitable estoppel or laches against the Department, and rejected the provider’s arguments regarding the sufficiency of the Department’s audit. View "PROFESSIONAL HOME HEALTH CARE V. COMMONWEALTH OF KENTUCKY CABINET FOR HEALTH AND FAMILY SERVICES" on Justia Law

Two minor plaintiffs attended a four-day overnight science camp operated by a private entity and organized by their public school district. After returning home, they and their parents alleged that, during the camp, they were exposed to discussions and lessons about gender identity, including being introduced to counselors who used “they/them” pronouns and being asked to state their own preferred pronouns. The plaintiffs also claimed they were not allowed to contact their parents to discuss these matters due to a camp policy prohibiting calls home. They asserted that these experiences caused them severe emotional distress and initiated professional therapy.The plaintiffs filed suit in the Superior Court of Orange County, asserting claims for intentional infliction of emotional distress (IIED) and negligent infliction of emotional distress (NIED) against both the camp operator and the school district. The camp operator responded with a special motion to strike under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16), arguing that the claims arose from protected speech on matters of public interest—specifically, gender identity discussions. The trial court denied the anti-SLAPP motion, finding that the claims were not based on protected activity but rather on the lack of disclosure to parents and the prohibition on contacting them. The court also denied the plaintiffs’ request for attorney fees, finding the anti-SLAPP motion was not frivolous.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, held that the trial court erred in denying the anti-SLAPP motion in its entirety. The appellate court found that the IIED and NIED claims, to the extent they were based on exposure to gender identity discussions, arose from protected activity and lacked minimal merit, both factually and legally, under California public policy. However, claims based solely on the prohibition of calls home or sleeping arrangements did not arise from protected activity and could proceed. The order was affirmed in part, reversed in part, and remanded with directions. View "Sandoval v. Pali Institute" on Justia Law

After Congress enacted the Tax Cuts and Jobs Act in 2017, which capped the federal deduction for state and local taxes (SALT) at $10,000, New Jersey, New York, Connecticut, and the Village of Scarsdale created or planned programs allowing residents to make contributions to state-administered charitable funds in exchange for significant state or local tax credits. These programs were designed to help residents recover some of the lost federal tax benefit by allowing them to claim a federal charitable deduction for the full amount contributed, despite receiving a state or local tax credit in return. In response, the Internal Revenue Service (IRS) and Treasury Department issued a regulation (the “Final Rule”) requiring taxpayers to reduce their federal charitable deduction by the amount of any state or local tax credit received for the contribution.The States and Scarsdale sued the IRS and Treasury in the United States District Court for the Southern District of New York, arguing that the Final Rule exceeded the IRS’s statutory authority under 26 U.S.C. § 170 and was arbitrary and capricious under the Administrative Procedure Act. The district court granted summary judgment for the government, finding the IRS’s interpretation reasonable under Chevron deference and holding the rule was not arbitrary or capricious.On appeal, the United States Court of Appeals for the Second Circuit determined that New York and Scarsdale had Article III standing, and that the Anti-Injunction Act did not bar the suit because there was no alternative procedure for the plaintiffs to challenge the rule. Applying the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overruled Chevron, the Second Circuit independently interpreted § 170 and concluded that the IRS’s rule was consistent with the statute’s quid pro quo principle. The court also found the rule was not arbitrary or capricious. The Second Circuit affirmed the district court’s judgment. View "New Jersey v. Bessent" on Justia Law

The case concerns the executive branch’s decision to freeze foreign aid funds that Congress had appropriated for fiscal year 2024. On January 20, 2025, the President issued an executive order directing the State Department and USAID to pause foreign assistance spending, pending a review of those programs. This led to the suspension or termination of thousands of grant awards and significant restructuring within the agencies. Organizations that were recipients of these funds, many of which relied heavily on such funding, challenged the executive order, arguing that the freeze unlawfully impounded funds that Congress had directed to be spent.The United States District Court for the District of Columbia initially granted a temporary restraining order, and later a preliminary injunction, against the executive branch (excluding the President personally). The district court found that the plaintiffs had standing due to financial harm, and that they were likely to succeed on their claims that the executive branch’s actions violated the separation of powers, the Take Care Clause, the Impoundment Control Act (ICA), the Anti-Deficiency Act, and the Administrative Procedure Act (APA). The court ordered the government to make available the full amount of appropriated funds.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and vacated the district court’s preliminary injunction. The appellate court held that the plaintiffs lacked a cause of action to pursue their claims. Specifically, it found that the plaintiffs could not bring a freestanding constitutional claim when the alleged violations were statutory in nature, that the ICA precludes APA review by private parties (reserving enforcement to the Comptroller General), and that the plaintiffs could not reframe their claims as ultra vires actions. The court concluded that, although the plaintiffs had standing, they were not entitled to the preliminary injunction because they were unlikely to succeed on the merits. View "Global Health Council v. Trump" on Justia Law

Shareholders of Fannie Mae and Freddie Mac, acting derivatively on behalf of these entities, challenged the federal government’s actions following the 2008 financial crisis. After the housing market collapse, Congress passed the Housing and Economic Recovery Act of 2008 (HERA), creating the Federal Housing Finance Agency (FHFA) and authorizing it to act as conservator for the Enterprises. The FHFA placed both entities into conservatorship, and the U.S. Treasury entered into agreements to provide financial support in exchange for senior preferred stock and other rights. In 2012, a “net worth sweep” was implemented, redirecting nearly all profits from the Enterprises to the Treasury, effectively eliminating dividends for other shareholders. The plaintiffs, as preferred shareholders, alleged that this arrangement constituted an unconstitutional taking under the Fifth Amendment.The United States Court of Federal Claims previously reviewed the case and granted the government’s motion to dismiss. The Claims Court relied on the Federal Circuit’s prior decision in Fairholme Funds, Inc. v. United States, which held that, under HERA, the Enterprises lost any cognizable property interest necessary to support a takings claim because the FHFA, as conservator, had broad authority over the Enterprises’ assets. The Claims Court found the plaintiffs’ claims indistinguishable from those in Fairholme and dismissed them accordingly.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the dismissal de novo. The court affirmed the Claims Court’s decision, holding that claim preclusion barred the plaintiffs’ derivative takings claims because the issues had already been litigated in Fairholme. The court rejected arguments that the prior representation was inadequate or that the Supreme Court’s subsequent decision in Tyler v. Hennepin County fundamentally changed takings law. The Federal Circuit concluded that Fairholme remained binding precedent and affirmed the dismissal. View "FISHER v. US " on Justia Law

Victory Insurance Company, a Montana property and casualty insurer, issued workers’ compensation policies to several businesses in 2019. Later that year, Victory entered into an agreement with Clear Spring Property and Casualty Company to reinsure and then purchase Victory’s book of business, including the relevant policies. Victory notified its insureds by phone and sent a single email on December 31, 2019, stating that their policies would be “upgraded” to Clear Spring policies effective January 1, 2020. All policies were rewritten under Clear Spring as of that date.The Montana Commissioner of Securities & Insurance (CSI) initiated an enforcement action in December 2022, alleging that Victory had illegally cancelled its policies and could be fined up to $2.7 million. After discovery, both parties moved for summary judgment before a CSI Hearing Examiner. The Hearing Examiner found that Victory committed 165 violations of Montana’s insurance code and recommended summary judgment for the CSI. The CSI adopted this recommendation, imposing a $250,000 fine with $150,000 suspended, payable only if further violations occurred within a year. Victory sought judicial review in the First Judicial District Court, Lewis and Clark County, which affirmed the CSI’s decision.The Supreme Court of the State of Montana reviewed the case, applying the same standards as the district court. The Court held that the Hearing Examiner properly granted summary judgment because Victory’s actions constituted cancellations under the insurance code, regardless of whether they could also be considered assignments. The Court also held that Victory’s due process rights were not violated during the fine imposition process, that the statutory delegation of fine authority to the CSI was constitutional, and that Victory was not entitled to a jury trial because there were no material factual disputes. The Supreme Court affirmed the district court’s order. View "Victory Insurance v. State" on Justia Law

A group of professional auctioneers in Tennessee, including both licensed and unlicensed individuals, challenged a state law requiring auctioneers to obtain a license before conducting extended-time online auctions. The law, originally enacted in 1967 and updated in 2019 to address online auction formats, exempts certain types of online sales, such as fixed-price listings and timed listings that do not extend based on bidding activity. The plaintiffs, who conduct extended-time online auctions, argued that the licensing requirement infringed on their First Amendment rights by restricting their ability to communicate with potential buyers and craft narratives about auction items.Previously, one of the plaintiffs, McLemore, filed a lawsuit in the United States District Court for the Middle District of Tennessee, challenging the law under both the First Amendment and the Dormant Commerce Clause. The district court granted summary judgment on the Dormant Commerce Clause claim but did not address the First Amendment issue. The United States Court of Appeals for the Sixth Circuit vacated that decision for lack of standing and remanded with instructions to dismiss. Subsequently, McLemore and additional plaintiffs filed a new lawsuit, focusing on the First Amendment claim. The district court dismissed the case, holding that the law regulated professional conduct rather than speech and applied rational basis review, relying on the Sixth Circuit’s prior decision in Liberty Coins, LLC v. Goodman.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The court held that Tennessee’s licensing requirement for auctioneers regulates economic activity and professional conduct, not speech, and that any burden on speech is incidental. The court applied rational basis review and concluded that the law is rationally related to the state’s legitimate interest in preventing fraud and incompetence in auctioneering. The judgment of the district court was affirmed. View "McLemore v. Gumucio" on Justia Law

The case concerns a challenge to an executive order issued by the President in January 2025, which established the Department of Government Efficiency (DOGE) and required federal executive agencies to create internal DOGE Teams with broad IT access to agency systems. Plaintiffs, consisting of several professional organizations and individuals, alleged that granting such access to DOGE-affiliated employees would expose their personally identifiable information in violation of the Privacy Act and the Administrative Procedure Act (APA). They sought to enjoin the Department of Education, the Office of Personnel Management (OPM), and the Department of the Treasury from providing this access.The United States District Court for the District of Maryland initially granted a temporary restraining order, and later a preliminary injunction, halting the agencies’ DOGE Teams from accessing the IT systems. The government appealed the preliminary injunction to the United States Court of Appeals for the Fourth Circuit, which stayed the injunction pending appeal. During the appeal, the Supreme Court stayed a similar injunction in a related case involving the Social Security Administration.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision under an abuse of discretion standard. The Fourth Circuit held that the district court erred in its analysis of the plaintiffs’ likelihood of success on the merits, particularly by failing to account for the cumulative difficulty plaintiffs faced in prevailing on multiple independent legal issues necessary for relief. The appellate court found that plaintiffs likely lacked standing, and even if standing existed, there were substantial unresolved questions regarding final agency action, the adequacy of remedies under the APA, and whether the Privacy Act’s exceptions applied. The Fourth Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "American Federation of Teachers v. Bessent" on Justia Law

Terri R. Winnon, a former executive assistant and controller for a group of skilled nursing facilities (SNFs) in Texas, alleged that her former employers and associated entities engaged in fraudulent schemes to obtain improper reimbursements from Medicare and Texas Medicaid. She claimed that the defendants paid unlawful kickbacks to doctors and hospital discharge planners for patient referrals and inflated therapy service bills to maximize government reimbursements. Winnon’s allegations included specific practices such as employee bonuses tied to Medicare census targets, “sham” medical directorships, and “marketing gifts” to hospital staff, as well as systematic upcoding of therapy services by a contracted provider, RehabCare.After Winnon filed her qui tam action under the False Claims Act (FCA) and related Texas statutes, the United States District Court for the District of Columbia dismissed her claims. The court found that her allegations against RehabCare were barred by the FCA’s public disclosure provision, as similar claims had already been made public in a prior lawsuit, United States ex rel. Halpin & Fahey v. Kindred Healthcare, Inc. The district court also determined that Winnon’s claims against the SNF Defendants did not meet the heightened pleading requirements of Federal Rule of Civil Procedure 9(b), as they lacked sufficient particularity regarding the alleged fraudulent conduct.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissals. The appellate court held that Winnon’s claims against RehabCare were precluded by the public disclosure bar because her allegations were substantially similar to those previously disclosed and she did not qualify as an “original source” under the FCA. Regarding the SNF Defendants, the court concluded that Winnon’s allegations failed to satisfy Rule 9(b)’s requirement for particularity, as she did not provide enough specific details to support a strong inference that false claims were actually submitted. The court affirmed the district court’s judgments in full. View "USA v. Lozano" on Justia Law