Justia Government & Administrative Law Opinion Summaries

A man named Yoon Suk Chang was injured at the American Memorial Park on Saipan when his foot got caught in a large hole in a grassy area. He suffered severe ankle injuries, which required surgery and led to significant medical expenses and financial losses. Chang filed a negligence claim under the Federal Tort Claims Act (FTCA) against the United States, alleging that the National Park Service (NPS) allowed a dangerous hole to go unrepaired.The District Court for the Northern Mariana Islands dismissed Chang's complaint, citing the discretionary function exception of the FTCA. The court reasoned that the decisions on how to inspect and maintain the grassy areas involved policy considerations, such as safety, public access, and aesthetics. Therefore, the court concluded that the discretionary function exception applied, and the United States was immune from the lawsuit.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's judgment. The Ninth Circuit held that the discretionary function exception did not apply because the routine maintenance of a grassy lawn did not involve government employees balancing public policy considerations. The court emphasized that the NPS's failure to repair a hole in a regularly maintained grass area was a matter of routine maintenance, which is not protected by the discretionary function exception. The case was remanded for further proceedings consistent with this opinion. View "Chang v. United States" on Justia Law

Albert Lobo, a Deputy Sheriff in San Bernardino County, California, contracted pneumonia in early 2010, which progressed to sepsis and resulted in multiple amputations, leaving him permanently and totally disabled. He received disability retirement and workers' compensation benefits at the county and state levels between 2012 and 2014. In March 2015, Lobo filed a claim for disability-based benefits under the Public Safety Officers’ Benefits Act of 1976 (PSOB Act) with the Public Safety Officers’ Benefits Office (PSOB Office) of the Bureau of Justice Assistance (Bureau) of the U.S. Department of Justice.The PSOB Office denied Lobo's claim in May 2016, a decision upheld by a hearing officer in October 2017 and the Bureau’s Director in August 2023. The denials were based on the finding that Lobo had not proven he contracted pneumonia in the line of duty. The Bureau's Director emphasized the lack of evidence showing that Lobo caught pneumonia at the jails where he worked, despite acknowledging that Lobo was permanently and totally disabled due to pneumonia.The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the Bureau had not made sufficient efforts to obtain potentially crucial information about whether there were pneumonia-infected individuals at the jails where Lobo worked. The court noted that such information could be highly material to determining the origin of Lobo's pneumonia. Consequently, the court vacated the Director’s decision and remanded the case for further proceedings, instructing the Bureau to make reasonable efforts to obtain the necessary information from the jails and to reassess the claim in light of any new evidence obtained. View "Lobo v. Department of Justice" on Justia Law

In this case, Sacramento Television Stations Inc. (Sac TV) sought additional audio and video recordings from the City of Roseville (City) under the California Public Records Act (CPRA). The recordings pertained to an incident on April 6, 2023, where Roseville Police Department (Roseville PD) officers discharged firearms at a suspect, Eric J. Abril, resulting in injuries and a fatality. The City provided limited footage, arguing that further disclosure would interfere with an active investigation.The Superior Court of Placer County ruled that the City had shown by clear and convincing evidence that releasing more footage would substantially interfere with the ongoing investigation into Abril's criminal case. Consequently, the court denied Sac TV's petition for additional recordings. Sac TV then filed a petition for writ of mandate in the California Court of Appeal, Third Appellate District, seeking to overturn the superior court's decision.The California Court of Appeal reviewed the case and concluded that the superior court's finding of an "active investigation" was not supported by substantial evidence. The appellate court determined that the City had not provided sufficient detail to demonstrate how further disclosure would interfere with an active investigation. The court also found that the superior court correctly interpreted that more disclosure was required under subdivision (e) of section 7923.625 of the Government Code, but it had not determined the extent of additional disclosure needed.The Court of Appeal vacated the superior court's ruling and directed it to hold further proceedings, including an in camera review of the City's recordings, to determine the extent of additional disclosure required. The appellate court emphasized the importance of providing sufficient context to understand the events captured in the recordings, as mandated by the CPRA. View "Sacramento Television Stations Inc. v. Superior Court" on Justia Law

The plaintiffs, a group of consumers, filed a lawsuit against General Motors (GM) and Robert Bosch LLC, alleging that the companies misled consumers about the emissions produced by certain Chevrolet Cruze vehicles. They claimed that the vehicles emitted higher levels of nitrogen oxides (NOx) than advertised and that the emissions control systems were manipulated to pass regulatory tests. The plaintiffs sought damages under various state fraud laws and the Racketeer Influenced and Corrupt Organizations (RICO) Act.The United States District Court for the Eastern District of Michigan initially dismissed some of the plaintiffs' claims, ruling that those based on the Environmental Protection Agency (EPA) standards were preempted by the Clean Air Act. The court allowed other claims to proceed, particularly those alleging that GM's advertising misled consumers about the vehicles' emissions. However, after the Sixth Circuit's decision in a similar case (In re Ford Motor Company F-150 and Ranger Truck Fuel Economy Marketing and Sales Practices Litigation), the district court revisited its decision and dismissed the remaining fraud claims, concluding they were preempted by federal law. The court also granted summary judgment to the defendants on the RICO claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court should determine whether the plaintiffs' remaining claims could proceed without relying on a disagreement with the EPA's determinations. The court remanded the case for the district court to decide if the claims were preempted under the analysis described. The court affirmed the dismissal of the RICO claims and the denial of the plaintiffs' post-judgment motion to vacate the judgment in part and approve a preliminary settlement agreement. The case was remanded for further proceedings consistent with the opinion. View "Counts v. General Motors, LLC" on Justia Law

A reporter for The Providence Journal submitted an Access to Public Records Act (APRA) request to the Office of Governor Daniel J. McKee, seeking a list of individuals who received preferred license plates. The Governor’s Office denied the request, citing the federal Driver’s Privacy Protection Act (DPPA) and state law, which protect such information from disclosure. The Providence Journal argued that the DPPA did not apply because the records were maintained by the Governor’s Office, not the Department of Motor Vehicles (DMV).The Rhode Island Office of the Attorney General upheld the Governor’s Office’s denial, stating that the Governor’s Office effectively acts as an agent of the DMV in this context. LMG Rhode Island Holdings, Inc., the publisher of The Providence Journal, then filed a complaint for declaratory and injunctive relief in the Superior Court, arguing that the denial violated APRA. The Superior Court dismissed the complaint, agreeing with the Attorney General that the DPPA applied to the Governor’s Office in this context and that the requested information was exempt from disclosure under APRA.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court’s judgment. The Court held that the DPPA applies to the Governor’s Office when it processes preferred plate applications, as it acts as an agent of the DMV. The Court also concluded that the information requested was protected by the DPPA, as it pertains to motor vehicle registration records. Consequently, the denial of the APRA request was lawful.Additionally, the Supreme Court affirmed the Superior Court’s denial of the Governor’s Office’s motion for attorneys’ fees. The Court found that the plaintiff’s case had some grounding in existing law and was not frivolous, thus not warranting an award of attorneys’ fees. View "LMG Rhode Island Holdings, Inc. v. Office of Governor McKee" on Justia Law

Abigail Stratton filed a petition with the Office of Special Masters under the National Childhood Vaccine Injury Act, alleging that the Gardasil® vaccine caused her to develop postural orthostatic tachycardia syndrome (POTS) and autonomic dysfunction. These conditions are not listed in the Vaccine Injury Table, requiring her to prove actual causation by a preponderance of the evidence. After filing a Notice of Intent to Withdraw to pursue her claim in federal district court, the Chief Special Master concluded the proceedings on the merits and later awarded her partial attorneys’ fees and costs.The Secretary of Health and Human Services opposed the fee application, arguing that Stratton did not file her petition with the good faith intent of litigating the claim and that there was no reasonable basis for her claim. The Chief Special Master found that Stratton had satisfied both the good faith and reasonable basis requirements and awarded partial fees. The Court of Federal Claims affirmed the Chief Special Master’s decision, concluding that the finding of a reasonable basis was not arbitrary and capricious, and awarded $8,876.86 for attorneys’ fees and costs. The Secretary appealed this decision.The United States Court of Appeals for the Federal Circuit reviewed the case and found that the Chief Special Master failed to adequately explain the determination that Stratton’s petition had a reasonable basis. The court noted that the Chief Special Master acknowledged the Secretary’s concerns about the sufficiency of the medical records but dismissed them without sufficient explanation. The Federal Circuit vacated the decision and remanded the case for further proceedings consistent with its opinion, requiring a more detailed explanation of why the evidence provided a reasonable basis for Stratton’s claim. View "Stratton v. Health and Human Services" on Justia Law

The case involves the Federal Energy Regulatory Commission (FERC) extending the construction deadline for the Mountain Valley Pipeline, LLC (MVP) Southgate Project. Initially, FERC issued a certificate of public convenience and necessity for the Southgate Project in June 2020, setting a construction completion deadline of June 18, 2023. However, due to unresolved permitting issues for the Mainline, which Southgate extends from, the construction could not proceed as planned. MVP requested an extension shortly before the deadline, citing delays in Mainline permitting as the reason for not meeting the original deadline.The Commission granted MVP's extension request, finding that MVP had demonstrated good cause due to unavoidable circumstances, specifically the Mainline permitting delays. FERC also maintained that its previous assessments of market need and environmental impacts for the Southgate Project remained valid and did not require reevaluation.Eight environmental organizations petitioned for review, arguing that FERC's decision to extend the construction deadline and its refusal to revisit prior assessments were arbitrary and capricious. They contended that MVP had not made reasonable efforts to advance the Southgate Project and that the market need and environmental impact analyses were outdated.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that FERC reasonably found that MVP had satisfied the good cause standard for the extension, given the permitting and litigation delays with the Mainline. The court also upheld FERC's decision not to revisit its prior findings on market need and environmental impacts, concluding that the information presented by the petitioners did not constitute significant changes in circumstances. Consequently, the court denied the petitions for review. View "Appalachian Voices v. Federal Energy Regulatory Commission" on Justia Law

A Nebraska county (Hayes) sought reimbursement from a neighboring county (Frontier) for half the cost of replacing a bridge under Neb. Rev. Stat. § 39-827 et seq. Hayes claimed the bridge was on a county line road, thus requiring shared expenses. Frontier's board of commissioners denied the claim, arguing the bridge was not on a county line road and that Frontier was not equally interested in the bridge. Hayes then filed a petition in error in the district court, seeking review of the board's decision.The district court reviewed the case and found that Hayes had not provided sufficient evidence to support its claim. Specifically, the court noted that Hayes did not request an evidentiary hearing before the Frontier Board, resulting in a lack of formal proof regarding the bridge's location. The court concluded that the only evidence in the record was Hayes' claim and its attachments, which were insufficient to establish the bridge's location as required by § 39-827. Consequently, the district court denied and dismissed Hayes' petition in error.On appeal, the Nebraska Supreme Court reviewed whether the Frontier Board acted within its jurisdiction and whether its decision was supported by sufficient relevant evidence. The court found that Hayes failed to meet its burden of proof to demonstrate that the bridge was on a county line road as defined by § 39-1403. The court also noted that the Road Agreement between Hayes and Frontier did not conclusively establish the bridge's location for the purposes of the bridge statutes. The Supreme Court affirmed the district court's judgment but modified the disposition from "denied and dismissed" to "affirmed." View "County of Hayes v. County of Frontier" on Justia Law

Catholic Charities Bureau, Inc., and its subentities sought an exemption from Wisconsin's unemployment compensation taxes, claiming they were controlled by the Roman Catholic Diocese of Superior and operated primarily for religious purposes. The Wisconsin Supreme Court denied the exemption, ruling that the organizations did not engage in proselytization or limit their services to Catholics, and thus were not operated primarily for religious purposes.The Wisconsin Department of Workforce Development initially denied the exemption request, but an Administrative Law Judge reversed this decision. The Wisconsin Labor and Industry Review Commission then reinstated the denial. The state trial court overruled the commission, granting the exemption, but the Wisconsin Court of Appeals reversed this decision. The Wisconsin Supreme Court affirmed the Court of Appeals, holding that the organizations' activities were secular and not primarily religious, and that the statute did not violate the First Amendment.The United States Supreme Court reviewed the case and held that the Wisconsin Supreme Court's application of the statute violated the First Amendment. The Court found that the statute imposed a denominational preference by differentiating between religions based on theological lines, subjecting it to strict scrutiny. The Court concluded that the statute, as applied, could not survive strict scrutiny because the State failed to show that the law was narrowly tailored to further a compelling government interest. The judgment of the Wisconsin Supreme Court was reversed, and the case was remanded for further proceedings. View "Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission" on Justia Law

Devas Multimedia Private Ltd. entered into a satellite-leasing agreement with Antrix Corporation Ltd., a company owned by the Republic of India. The agreement was terminated by Antrix under a force majeure clause when the Indian Government decided it needed more satellite capacity for itself. Devas initiated arbitration, and the arbitral panel awarded Devas $562.5 million in damages plus interest. Devas sought to confirm the award in the United States District Court for the Western District of Washington, which confirmed the award and entered a $1.29 billion judgment against Antrix.The United States Court of Appeals for the Ninth Circuit reversed the District Court's decision, finding that personal jurisdiction was lacking. The Ninth Circuit held that under the Foreign Sovereign Immunities Act of 1976 (FSIA), personal jurisdiction over a foreign state requires not only an immunity exception and proper service but also a traditional minimum contacts analysis as set forth in International Shoe Co. v. Washington. The court concluded that Antrix did not have sufficient suit-related contacts with the United States to establish personal jurisdiction.The Supreme Court of the United States reviewed the case and held that personal jurisdiction under the FSIA exists when an immunity exception applies and service is proper. The Court determined that the FSIA does not require proof of minimum contacts beyond the contacts already required by the Act’s enumerated exceptions to foreign sovereign immunity. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with its opinion. View "CC/Devas (Mauritius) Ltd. v. Antrix Corp." on Justia Law