Justia Government & Administrative Law Opinion Summaries

Plaintiffs-Appellants, owners of bonds issued by the Puerto Rico Sales Tax Financing Corporation (COFINA), sued the United States, alleging a taking of their property under the Fifth Amendment due to the enactment of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). They claimed that the restructuring of COFINA's debts under PROMESA resulted in a significant loss of the principal and interest value of their bonds and their security interest.The United States Court of Federal Claims determined it had subject matter jurisdiction over the case but dismissed it for failure to state a claim. The court found that the enactment of PROMESA by Congress did not constitute sufficient federal government action to support a takings claim. The court reasoned that the actions of the Puerto Rico Oversight Board, which was created by PROMESA and acted autonomously, could not be attributed to the United States as coercive or as an agency relationship.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the decision of the Claims Court. The Federal Circuit held that PROMESA did not displace Tucker Act jurisdiction, as there was no clear congressional intent to withdraw the Tucker Act remedy. The court also agreed with the Claims Court that the United States did not exert coercive control over the Oversight Board's actions, which were necessary to establish a taking. The court concluded that the plaintiffs could not establish that the United States was liable for the alleged taking of their property. The court also found no abuse of discretion in the Claims Court's decision to deny the plaintiffs' request to amend their complaint. View "DINH v. US " on Justia Law

In 1996, California voters enacted Proposition 218, adding article XIII D to the California Constitution, which includes section 6(b)(3). This section mandates that governmental fees or charges imposed on property must not exceed the proportional cost of the service attributable to the parcel. Plaintiffs, representing a class of single-family residential (SFR) customers of the City of San Diego, challenged the City's tiered water rates, claiming they violated section 6(b)(3) by exceeding the proportional cost of delivering water.The Superior Court of San Diego County ruled in favor of the plaintiffs, finding that the City's tiered rates did not comply with section 6(b)(3). The court concluded that the City failed to show that its tiered rates were based on the actual cost of providing water at different usage levels. The court found that the City's tiered rates were designed to encourage conservation rather than reflect the cost of service, and that the City's use of peaking factors and other methodologies lacked supporting data.The Court of Appeal of the State of California, Fourth Appellate District, Division Two, reviewed the case. The court affirmed the lower court's decision, holding that the City did not meet its burden of proving that its tiered rates complied with section 6(b)(3). The appellate court found that substantial evidence supported the trial court's findings that the City's tiered rates were not cost-proportional and that the City's methodologies were not adequately supported by data. The court also addressed the issue of class certification, finding that the class was properly certified and that the plaintiffs had a common interest in challenging the City's rate structure.The appellate court directed the trial court to amend the judgment to allow the City to satisfy the refund award pursuant to newly enacted Government Code section 53758.5, which requires agencies to credit refund awards against future increases in or impositions of the property-related charge. The court denied the plaintiffs' request for attorney fees on appeal without prejudice, allowing the trial court to determine the entitlement to such fees. View "Patz v. City of S.D." on Justia Law

Residents of the City of Page proposed an initiative to prevent the narrowing of a specific street within the city as part of a larger Streetscape Project aimed at economic development. The initiative sought to maintain the current size and number of lanes on Lake Powell Boulevard and prohibit the use of public or external funds to reduce its width. The City of Page rejected the initiative, deeming it non-legislative, and refused to place it on the ballot. Consequently, the Page Action Committee and individual plaintiffs filed a special action complaint in the superior court.The Superior Court in Coconino County found the initiative to be non-legislative in nature and ruled in favor of the City. The plaintiffs appealed to the Arizona Court of Appeals, Division One, which affirmed the lower court's decision. The appellate court applied a three-part test from Wennerstrom v. City of Mesa to determine whether the initiative was legislative or administrative. It concluded that the initiative was administrative because it only affected a specific portion of the road and sought to control the implementation of an already established policy.The Supreme Court of the State of Arizona reviewed the case and reversed the lower courts' decisions. The Court held that the initiative was legislative in nature because it created a new public policy and provided the means for its implementation. The Court emphasized that the citizens' power to legislate is coextensive with that of their elected representatives and that the initiative proposed a law, not an administrative action. The decision of the Court of Appeals was vacated, and the case was remanded to the trial court with instructions to enter appropriate relief for the plaintiffs. View "ROUNDTREE v. PAGE" on Justia Law

The Center for Investigative Reporting and Will Evans requested several years of workforce composition reports from the U.S. Department of Labor under the Freedom of Information Act (FOIA). These reports, filed by federal contractors, detail the job categories and demographics of their employees. The Center intended to use this information to report on the diversity of these contractors' workforces. The Department of Labor withheld many of the requested reports, citing FOIA’s Exemption 4, which protects confidential commercial information.The United States District Court for the Northern District of California reviewed the case and ordered the Department to disclose the reports. The court found that the information in the reports did not qualify as "commercial" under Exemption 4 because it did not reveal commercially significant insights about the contractors' operations. The Department of Labor appealed this decision.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s order. The Ninth Circuit held that the workforce-composition information in the reports did not constitute "commercial" information under Exemption 4. The court reasoned that the data on the number of employees in various job categories and their demographics did not directly describe the exchange of goods or services or the making of a profit. The court concluded that the Department of Labor failed to demonstrate that the information in the reports was commercial in nature, and therefore, the reports must be disclosed. The court did not address other elements of Exemption 4 or the FOIA Improvement Act, as the determination on the commercial nature of the information was sufficient to resolve the case. View "CENTER FOR INVESTIGATIVE REPORTING V. UNITED STATES DEPARTMENT OF LABOR" on Justia Law

A skilled nursing facility accepted a new resident who was receiving Medicaid benefits. The resident's husband was designated as her authorized representative. Nearly two years later, the Department of Human Services (DHS) terminated the resident's Medicaid benefits due to excess assets. Both the resident and her husband were incapacitated, and the resident's public guardian submitted a new Medicaid application, which was denied. The nursing facility continued to care for the resident without compensation until her death. The facility later sought an administrative hearing to challenge the eligibility decision, but the request was denied because the facility was not an authorized representative and the appeal was late.The circuit court and the Intermediate Court of Appeals (ICA) affirmed the denial, holding that the nursing home lacked standing to challenge the eligibility determination under Hawai'i Revised Statutes (HRS) § 346-12, which limits appeals to the applicant or recipient. The courts concluded that the nursing home did not have a close relationship with the resident for third-party standing purposes.The Supreme Court of the State of Hawai'i reviewed the case and disagreed with the lower courts regarding standing. The court held that skilled nursing facilities have constitutionally protected property interests in compensation for medical services performed for residents based on DHS eligibility determinations. The court ruled that these facilities have due process rights under the Hawai'i Constitution, including notice and the opportunity to appeal Medicaid eligibility determinations when the beneficiary is incapacitated and no authorized representative is available or willing to appeal. The court vacated the ICA's judgment and the circuit court's order, remanding the case for a new administrative hearing on the merits of the resident's Medicaid eligibility. View "In re FT" on Justia Law

Henry Walters bequeathed the Walters Art Gallery, adjacent property, and all their contents to the Mayor and City Council of Baltimore in 1931. The City established a board of trustees to manage the assets, and in 1933, the General Assembly incorporated the Trustees of the Walters Art Gallery as an educational corporation with full control over the property. The Board has since operated the Walters Art Gallery, now known as the Walters Art Museum, for public benefit.The Circuit Court for Baltimore City ruled in favor of the plaintiffs, Walters Workers United and AFSCME, who sought to compel the Board to produce records under the Maryland Public Information Act (MPIA). The court concluded that the Board was a governmental instrumentality subject to the MPIA. The Appellate Court of Maryland affirmed this decision, emphasizing the Board's public purpose, City ownership of the property, and financial support from the City.The Supreme Court of Maryland reviewed the case and reversed the lower courts' decisions. The Court held that the Board is not a governmental unit or instrumentality under the MPIA. The Court emphasized the Board's operational independence, its fiduciary role in carrying out a private donor's charitable intent, and the lack of substantial City control over its operations. The Court concluded that the Board's relationship with the City does not make it a governmental instrumentality subject to the MPIA. The case was remanded to the Appellate Court of Maryland with instructions to remand to the Circuit Court for further proceedings consistent with this opinion. View "Walters Art Gallery v. Walters Workers United" on Justia Law

Sun Valley Orchards, a New Jersey farm, was accused by the U.S. Department of Labor (DOL) of breaching an employment agreement under the H-2A nonimmigrant visa program. The DOL alleged that Sun Valley failed to provide adequate housing, meal plans, transportation, and guaranteed work hours to its workers, as stipulated in the job order. The DOL imposed civil penalties and back wages totaling hundreds of thousands of dollars through administrative proceedings.The case was first reviewed by an Administrative Law Judge (ALJ), who affirmed most of the DOL's findings but slightly modified the penalties and back wages. Sun Valley then appealed to the Administrative Review Board, which upheld the ALJ's decision. Subsequently, Sun Valley challenged the DOL's decision in the United States District Court for the District of New Jersey, arguing that the administrative proceedings violated Article III of the Constitution, among other claims. The District Court dismissed Sun Valley's claims, holding that the DOL's actions fit within the public-rights doctrine and that the agency had statutory authority to impose penalties and back wages.The United States Court of Appeals for the Third Circuit reviewed the case and held that Sun Valley was entitled to have its case decided by an Article III court. The court found that the DOL's enforcement action resembled a common law breach of contract suit, which traditionally would be heard in a court of law. The court also determined that the case did not fit within the public rights exception to Article III adjudication, as the H-2A labor certification regulations primarily concern domestic employment law rather than immigration control. Consequently, the Third Circuit reversed the District Court's decision and remanded the case with instructions to enter judgment in favor of Sun Valley. View "Sun Valley Orchards LLC v. United States Department of Labor" on Justia Law

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