Justia Government & Administrative Law Opinion Summaries

A four-year-old child suffered severe brain damage due to a massive air embolism during surgery in July 2018. The child's parents, John and Amelia Tullis, sued the healthcare providers, including the University of Utah, in 2019, alleging negligence and seeking damages for pain, anguish, and future medical expenses estimated to exceed $22 million.The University of Utah sought to limit the potential recovery by invoking the 2017 Governmental Immunity Act of Utah (GIA), which capped damages at $745,200. The Third District Court of Salt Lake County denied the University's motion for partial summary judgment, reasoning that the decision in Condemarin v. University Hospital, which found a different damages cap unconstitutional as applied to University Hospital, necessarily determined that the 2017 GIA’s damages cap was also unconstitutional as applied to the University.The Utah Supreme Court reviewed the case to determine whether Condemarin controlled the current issue. The court concluded that Condemarin, a plurality decision with a narrow holding, did not control the case. The court noted that Condemarin’s holding was limited to the specific statutes at issue in that case, which imposed a $100,000 cap, whereas the 2017 GIA set a higher limit and included a mechanism for adjusting for inflation. The court emphasized that Condemarin’s holding did not automatically apply to the revised statute with different terms.The Utah Supreme Court reversed the district court’s decision and remanded the case for further proceedings, noting that the district court should consider the Tullises' request for discovery on the applicability of the damages cap. View "University of Utah Hospital v. Tullis" on Justia Law

Two Italian pasta manufacturers, La Molisana S.p.A. and Valdigrano Di Flavio Pagani S.r.L., challenged the United States Department of Commerce's final results from the twenty-third administrative review of an antidumping order on certain pasta from Italy. The dispute centered on Commerce's methodology for determining the protein content of pasta, which affects the classification of pasta as either standard or premium quality. Commerce used the protein content listed on product labels, which is subject to U.S. FDA rounding rules and different nitrogen-to-protein conversion factors in the U.S. and Italy. La Molisana argued that this methodology caused inaccuracies in comparing pasta products.The United States Court of International Trade sustained Commerce's final results, concluding that La Molisana had not demonstrated that the alleged flaws in Commerce's methodology were commercially significant. The court found that Commerce's reliance on packaging labels for protein content fostered transparency and consistency, and that La Molisana's evidence, including a market report and a new definition from the Bologna Grain Exchange, was insufficient to compel a change in the protein breakpoint from 12.5% to 13.5%.The United States Court of Appeals for the Federal Circuit reviewed the case and found that Commerce's methodology failed to compare products based on identical physical characteristics, as required by statute. The court held that the FDA rounding rules and different nitrogen conversion factors introduced inaccuracies that Commerce could not dismiss as commercially insignificant. However, the court agreed with Commerce and the Trade Court that La Molisana's evidence did not provide a compelling reason to change the protein breakpoint. The Federal Circuit vacated the Trade Court's judgment regarding the rounding rules and nitrogen conversion factors, affirmed the judgment on the protein breakpoint, and remanded for further proceedings. View "La Molisana S.p.A. v. United States" on Justia Law

A public interest law firm, TPM, requested certain budget-request documents from the Mayor of the District of Columbia under the D.C. Freedom of Information Act (D.C. FOIA). TPM sought documents related to the budget requests of the D.C. Public Schools (DCPS) and the Office of the State Superintendent of Education (OSSE) for fiscal year 2019, as well as other related documents. The Mayor refused to produce the draft submissions, claiming they were protected by executive privilege. TPM then filed a complaint in the Superior Court of the District of Columbia seeking the documents and their online publication.The Superior Court denied the Mayor's motion to dismiss and granted TPM's motion for summary judgment. The court ordered the Mayor to produce the requested documents and to comply with the publication requirements of D.C. Code § 2-536. The Mayor appealed, arguing that the documents were protected by executive privilege and that TPM lacked standing to enforce the publication provision.The District of Columbia Court of Appeals reviewed the case. The court rejected the Mayor's claim of executive privilege, stating that the budgetary process involves overlapping responsibilities between the Mayor and the Council, and thus does not fall under the exclusive purview of the executive branch. The court also found that TPM had standing to seek enforcement of the publication provision, as the failure to disclose the documents caused a concrete and particularized injury to TPM.The court affirmed the Superior Court's order requiring the production and online publication of the requested budget documents for fiscal years 2019 to the present. However, it vacated and remanded the portion of the order requiring the publication of other documents under D.C. Code § 2-536, instructing the lower court to clarify the scope of the required publication. View "District of Columbia v. Terris, Pravlik & Millian, LLP" on Justia Law

The U.S. Department of Education announced a reduction in force (RIF) on March 13, 2025, affecting about half of its employees. Subsequently, twenty-one states and several labor organizations and school districts filed lawsuits against the Secretary of Education, the Department, and the President, claiming that the RIF violated the U.S. Constitution and the Administrative Procedure Act (APA). They also sought an injunction against the transfer of certain functions out of the Department, announced by the President on March 21, 2025.The U.S. District Court for the District of Massachusetts consolidated the cases and granted the plaintiffs' motions for a preliminary injunction. The court found that the plaintiffs were likely to succeed on the merits of their claims, determining that the RIF and the transfer of functions were likely ultra vires and violated the APA. The court concluded that the actions were arbitrary and capricious, lacking a reasoned explanation and failing to consider the substantial harms to stakeholders.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the appellants' motion for a stay pending appeal. The court found that the appellants did not make a strong showing that they were likely to succeed on the merits, particularly regarding the APA claims. The court also determined that the plaintiffs would suffer substantial injury without the injunction, as the RIF made it effectively impossible for the Department to carry out its statutory functions. The court concluded that the public interest favored maintaining the injunction to ensure the Department could fulfill its legal obligations. View "New York v. McMahon" on Justia Law

Cascade County discovered petroleum contamination under a county shop complex in 1996 and notified the Department of Environmental Quality (DEQ). A 2000 report identified the contamination source as four county-owned tanks. The DEQ approved a corrective action plan in 2006, and the County requested the site be designated as a multiple release site for reimbursement eligibility, which the DEQ declined. The County completed remediation in 2008 and submitted receipts to the Montana Petroleum Tank Release Compensation Board, but the costs exceeded the statutory maximum for a single release. The Board indicated further reimbursement requests would be denied.The County sought a writ of mandamus to compel the DEQ to assign multiple release numbers, but the DEQ and the County eventually stipulated to dismiss the action in 2013. The County then filed four separate applications for reimbursement in 2014, which the Board denied, stating the DEQ had classified all contaminations under a single release number. The County contested this, and a Hearing Examiner found four discrete releases but ruled the claims were time-barred. The Board adopted most of the Examiner's findings but rejected the conclusion of four releases. The district court later ruled in favor of the County, and the Montana Supreme Court affirmed, directing the Board to reimburse the County.The Montana Supreme Court reviewed the case and determined that the Board had a clear legal duty to review the County's reimbursement claims, despite the County not submitting them in the manner required by Board regulations. The Court held that the Board must review and determine the eligibility of the claims submitted by the County for reimbursement of remediation costs. The District Court's order denying the County's writ of mandamus was reversed, and the case was remanded with instructions to issue the alternative writ of mandate. View "Cascade v. Petroleum Tank Release Compensation Board" on Justia Law

Jaime Norris applied for social security disability benefits and supplemental security income in October 2020, claiming disability due to various mental and physical disorders. The Social Security Administration denied his claim, leading Norris to request a hearing before an administrative law judge (ALJ). During the hearing, both Norris and a vocational expert testified. The ALJ concluded that Norris was not disabled under the Social Security Act, determining that he could adjust to other jobs existing in significant numbers in the national economy. Norris appealed to the Appeals Council, which denied his request for review, finalizing the ALJ's decision.Norris then sought judicial review in the United States District Court for the Northern District of Ohio. The district court affirmed the ALJ's decision, finding that substantial evidence supported the ALJ's conclusion. Norris subsequently appealed to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit reviewed whether the ALJ applied the correct legal standards and whether the findings were supported by substantial evidence. The court affirmed the ALJ's decision, holding that the vocational expert's testimony about the number of jobs available in the national economy constituted substantial evidence. The court rejected Norris's arguments that the ALJ erred in determining the number of significant jobs and that the district court improperly shifted the burden of proof. The court concluded that the ALJ's findings were reasonably drawn from the record and supported by substantial evidence, even if the evidence could support a contrary decision. View "Norris v. Commissioner of Social Security" on Justia Law

The National Association of Immigration Judges (NAIJ) challenged an Executive Office for Immigration Review (EOIR) policy requiring immigration judges to obtain prior approval before speaking publicly on immigration-related issues. NAIJ argued that this policy violated the First and Fifth Amendment rights of its members. The district court dismissed the case for lack of subject matter jurisdiction, concluding that the Civil Service Reform Act (CSRA) provided the exclusive remedy for such claims, requiring them to be brought through the administrative procedures established by the CSRA.The United States District Court for the Eastern District of Virginia dismissed the case, determining that the CSRA's comprehensive scheme for reviewing personnel actions against federal employees precluded the district court from exercising jurisdiction. The district court held that NAIJ's members must pursue their claims through the CSRA's administrative process, which includes review by the Merit Systems Protection Board (MSPB) and potential judicial review by the Federal Circuit.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court's decision. The Fourth Circuit held that while the CSRA generally precludes district court jurisdiction over such claims, the current functionality and independence of the MSPB and the Office of Special Counsel (OSC) were in question. The court noted that recent events, including the removal of the Special Counsel and the lack of a quorum in the MSPB, raised concerns about whether the CSRA's adjudicatory scheme was functioning as Congress intended. The Fourth Circuit remanded the case to the district court to conduct a factual inquiry into whether the CSRA continues to provide a functional and independent review process, as required for the jurisdiction-stripping scheme to apply. View "Natl Assn of Immigration Judges v. Owen" on Justia Law

Lalakshi Kale and Gurusaday Dey, both Indian nationals, have resided in the United States since 2009 and sought to obtain legal permanent residence based on Kale's employment. They applied for adjustment of status with the United States Citizenship and Immigration Services (USCIS) in 2022. Their applications were initially accepted because their priority dates were current. However, due to higher-than-expected demand, the final action date retrogressed, causing their applications to be held in abeyance under USCIS's adjudication hold policy until visa numbers become available.The United States District Court for the Eastern District of North Carolina dismissed the case for lack of jurisdiction, citing 8 U.S.C. § 1252(a)(2)(B)(ii), which precludes judicial review of discretionary decisions by the Attorney General or the Secretary of Homeland Security. The district court also noted an alternative basis for dismissal under the Administrative Procedure Act (APA) pursuant to 5 U.S.C § 701(a)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that USCIS's adjudication hold policy is a discretionary action under 8 U.S.C. § 1255(a), which grants the Attorney General the discretion to adjust the status of an alien and to prescribe regulations for such adjustments. The court found that this discretionary authority includes the implementation of the adjudication hold policy, thus falling under the jurisdiction-stripping provision of 8 U.S.C. § 1252(a)(2)(B)(ii). Consequently, the court concluded that it lacked jurisdiction to review the challenge to USCIS's policy and affirmed the dismissal of the case. View "Kale v. Alfonso-Royals" on Justia Law

Glen Lawson worked for coal-mining companies for twelve years and has a lengthy smoking history, smoking a pack a day for thirty years before quitting in 2014. He is now totally disabled due to respiratory ailments, including chronic obstructive pulmonary disease (COPD), and has used a portable oxygen tank since 2014, required lung surgery in 2017, and been hospitalized with pneumonia several times. In 2017, Lawson applied for benefits under the Black Lung Benefits Act.A claims examiner approved Lawson's application, and an administrative law judge (ALJ) upheld that determination. The Benefits Review Board affirmed the ALJ's decision. Lawson's former employer, Extra Energy, Inc., petitioned the United States Court of Appeals for the Fourth Circuit for review, arguing that Lawson did not provide sufficient evidence that his respiratory disabilities were attributable at least in part to his coal-mining employment rather than solely to his smoking history.The United States Court of Appeals for the Fourth Circuit reviewed the case and denied Extra Energy's petition for review. The court held that the ALJ sufficiently supported his conclusions regarding the cause of Lawson's disabilities. The ALJ credited the opinions of three medical experts who concluded that Lawson's respiratory and pulmonary ailments were caused by both his smoking history and his coal-mine employment, thus diagnosing him with legal pneumoconiosis. The court found that the ALJ's decision was supported by substantial evidence and consistent with applicable law, affirming the award of black-lung benefits to Lawson. View "Extra Energy, Incorporated v. DOWCP" on Justia Law

In August 2022, a bin full of phosphate rock collapsed at the Lee Creek Mine in Beaufort, North Carolina, injuring three miners. Industrial TurnAround Corporation (ITAC), the independent contractor responsible for checking the structural integrity of the bin's support columns, was cited by the Mine Safety and Health Administration (MSHA) for failing to take defective equipment out of service. MSHA sent a notice of proposed penalty to ITAC's outdated address of record, and ITAC did not contest the penalty, which became final 30 days later. ITAC subsequently filed a motion to reopen the penalty, claiming it had inadvertently failed to update its address of record.The Federal Mine Safety and Health Review Commission granted ITAC's motion to reopen the penalty, citing excusable neglect under Federal Rule of Civil Procedure 60(b). The Commission noted that ITAC had not occupied the address since 2009 and had only discovered the MSHA notice when an employee checked for missing packages. The Secretary of Labor, representing MSHA, opposed the motion, arguing that ITAC's failure to update its address could not be excused under FRCP 60(b).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Commission’s order to reopen the penalty was not an appealable collateral order and dismissed the Secretary’s petition for lack of jurisdiction. The court emphasized that the order did not impose an obligation, deny a right, or fix a legal relationship, and that the interest in immediate review did not meet the high threshold required under the collateral order doctrine. The court concluded that the Commission’s decision to reopen the penalty did not involve a substantial public interest or a particular value of a high order that justified immediate appeal. View "Secretary of Labor v. Industrial TurnAround Corporation" on Justia Law