Justia Government & Administrative Law Opinion Summaries

Teresa Williams and Barney's Childcare and Learning Center, Inc., doing business as Pooh Bear Academy, filed a complaint against various officials and employees of the Alabama Department of Human Resources (ADHR) and the Elmore County Department of Human Resources (EDHR). The complaint included tort claims related to the suspension and revocation of the day-care provider's operating license and the denial of its license renewal application.The Montgomery Circuit Court dismissed the complaint on April 25, 2024. Williams and the day-care provider filed a postjudgment motion to alter, amend, or vacate the judgment on May 23, 2024. The court set a hearing for July 1, 2024, but it did not occur. A hearing was eventually held on September 5, 2024, where both parties' counsel stated on record that they had agreed to extend the time for the court to rule on the postjudgment motion beyond the 90-day limit. However, the court did not enter an order denying the postjudgment motion until September 12, 2024.The Supreme Court of Alabama reviewed the case and determined that the appeal was untimely. The court noted that under Rule 59.1, Ala. R. Civ. P., the trial court had 90 days to rule on the postjudgment motion, which expired on August 21, 2024. Since the parties' consent to extend the time was not placed on the record before the 90-day period expired, the postjudgment motion was denied by operation of law on August 21, 2024. Consequently, Williams and the day-care provider had until October 2, 2024, to file their notice of appeal, but they did not do so until October 17, 2024. Therefore, the Supreme Court of Alabama dismissed the appeal for lack of jurisdiction. View "Williams v. Dodd" on Justia Law

In June 2020, the North Dakota Department of Health inspected ND Indoor RV Park, LLC and found several health, safety, and fire code violations. The Park was informed that its 2020 operating license would be revoked unless the violations were corrected. The Park did not address the violations, leading to the initiation of the license revocation process. The Park also requested a renewal of its license for 2021, which was denied due to the existing violations. The Park was allowed to operate until the hearing proceedings were final. The Park later withdrew its request for a hearing, and the Department of Health dismissed the renewal application and closed the case. Subsequently, the Park sold its property.The Park filed a complaint against the State of North Dakota, alleging regulatory taking, deprivation of substantive and procedural due process, inverse condemnation, unlawful interference with business relationships, systemic violation of due process, and estoppel. The State moved for judgment on the pleadings, claiming qualified immunity for individual defendants and lack of subject matter jurisdiction on the takings claims. The district court denied the State’s motion for summary judgment on the takings and due process claims but granted summary judgment on the unlawful interference claim. The remaining claims were dismissed by stipulation.The North Dakota Supreme Court reviewed the case. The court granted a writ of supervision, directing the district court to dismiss counts II and III because the individual defendants were entitled to qualified immunity. The court also directed the dismissal of counts I and IV for lack of subject matter jurisdiction, as the Park failed to exhaust administrative remedies. The court concluded that the Park could not prevail on its substantive and procedural due process claims and that the district court lacked jurisdiction over the takings claims. View "ND Indoor RV Park v. State" on Justia Law

AstraZeneca Pharmaceuticals LP and AstraZeneca AB challenged the Drug Price Negotiation Program created by the Inflation Reduction Act of 2022, which directs the Centers for Medicare & Medicaid Services (CMS) to negotiate prices for certain high-expenditure drugs. CMS issued guidance on selecting qualifying drugs for 2026, including Farxiga, manufactured by AstraZeneca. AstraZeneca sued the Secretary of the Department of Health and Human Services and the CMS Administrator, claiming the Negotiation Program violated procedural due process and that parts of CMS’s guidance violated the Administrative Procedure Act (APA).The United States District Court for the District of Delaware ruled that AstraZeneca failed to state a due process violation and lacked standing to pursue its APA claims. The court entered judgment in favor of the government.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that AstraZeneca lacked Article III standing to challenge the CMS guidance under the APA because the company did not demonstrate a concrete and particularized injury. AstraZeneca's claims about the impact on its business decision-making and difficulty valuing Farxiga in negotiations were deemed hypothetical and conjectural.Regarding the due process claim, the court held that AstraZeneca did not have a protected property interest in selling its drugs at a market rate. The court noted that federal patent laws do not confer a right to sell at a particular price, and the Negotiation Program only sets prices for drugs reimbursed by CMS, not private market transactions. Consequently, the court affirmed the District Court’s judgment, granting summary judgment in favor of the government on both the APA and due process claims. View "AstraZeneca Pharmaceuticals LP v. Secretary United States Department of Health and H" on Justia Law

John T. McFarland, a Program Support Specialist with the Department of Consumer and Regulatory Affairs (DCRA), requested a reclassification of his Grade 9 position to Grade 11 in 2011. The desk audit for this request was delayed, and the initial reviewer, Peter Delate, was replaced by Lewis Norman, who completed the audit in 2013 and concluded that the Grade 9 classification was correct. McFarland appealed this decision, but the Director of the District of Columbia’s Department of Human Resources (DCHR) upheld it. McFarland then petitioned for review in Superior Court, which affirmed DCHR’s decision. McFarland appealed to the District of Columbia Court of Appeals, which also affirmed the decision.In 2017, McFarland filed another petition in Superior Court, presenting new documents obtained through a Freedom of Information Act request that suggested Delate had initially supported a Grade 11 classification. The Superior Court vacated DCHR’s decision and remanded the case for reconsideration. On remand, a new specialist reviewed the entire record and concluded that McFarland’s position was correctly classified as Grade 9. McFarland again petitioned for review in Superior Court, which denied his petition and his motion for sanctions against the District of Columbia.The District of Columbia Court of Appeals reviewed the case and concluded that the Superior Court lacked jurisdiction to entertain McFarland’s petition for review under the Comprehensive Merit Personnel Act (CMPA), as the classification decision did not involve a reduction in grade. The court also found that McFarland had not shown that the Superior Court erred in denying his motion for sanctions. The Court of Appeals affirmed the denial of sanctions and remanded the case for dismissal of the petition for review for lack of jurisdiction. View "McFarland v. District of Columbia, Department of Human Resources" on Justia Law

Z.M., a non-verbal autistic child, attends the Center for Autism at Kiln Creek Elementary School. Through his father, he filed a lawsuit alleging that while being transported on a school bus, Newport News Public Schools employees struck him with a wet sock, verbally abused him, and allowed him to leave the bus partially unclothed. The complaint also mentioned previous verbal insults by school employees. Z.M. sought $15 million in compensatory and punitive damages, alleging negligence and gross negligence by the School Board and its employees.The Newport News School Board filed a plea in bar, claiming sovereign immunity. The Circuit Court of Newport News denied the plea regarding claims of simple and gross negligence but granted it concerning punitive damages, citing sovereign immunity. The School Board then filed an interlocutory appeal under Code §§ 8.01-626 and 8.01-670.2, which allow appeals from decisions on sovereign immunity pleas.The Supreme Court of Virginia reviewed the case de novo. The court concluded that Code § 22.1-194, which waives sovereign immunity when a vehicle is "involved in an accident," did not apply because the bus was not involved in an accident. The court held that the alleged acts did not relate to the operation of the bus as a vehicle. Consequently, the court reversed the circuit court's judgment and remanded the case for further proceedings. The court also noted that while the School Board is protected by sovereign immunity, the employees accused of gross negligence are not, allowing the lawsuit to proceed against them. View "Newport News School Board v. Z.M." on Justia Law

The Borough of Englewood Cliffs filed a complaint and an amended complaint against its former attorneys and a builder, alleging professional malpractice, breach of contract, unjust enrichment, civil conspiracy, and aiding and abetting. The Borough's actions followed a previous affordable housing litigation where the Borough did not prevail and subsequently settled with the builder. The Borough's new council, elected after a municipal election, pursued the litigation despite warnings from the defendants that the claims were frivolous.The trial court dismissed the Borough's complaints with prejudice, finding that the Borough acted in bad faith to harass, delay, and cause malicious injury. The court awarded the defendants attorney fees and costs under New Jersey’s Frivolous Litigation Statute (FLS), totaling $216,484.45. The Appellate Division affirmed the trial court's decision, concluding that a public entity is not immune from sanctions under the FLS.The Supreme Court of New Jersey reviewed the case and held that municipalities and municipal corporations that engage in frivolous litigation are subject to sanctions under the FLS. The Court found that the FLS does not provide immunity to municipalities and that the doctrine of sovereign immunity does not protect municipalities from liability under the FLS. The Court emphasized that the FLS aims to deter frivolous litigation and compensate the victims of such actions. The judgment of the Appellate Division was affirmed as modified, holding the Borough liable for the sanctions imposed. View "Borough of Englewood Cliffs v. Trautner" on Justia Law

A former president of Panama, while residing in the United States, was extradited to Panama under a bilateral treaty. Panama initially charged him with specific crimes, but after his extradition, he was prosecuted for additional money laundering crimes not included in the original extradition request. He claimed these prosecutions violated the treaty's rule of specialty, which restricts prosecution to the crimes listed in the extradition request unless the extradited individual has had the opportunity to return to the extraditing country.The United States District Court for the Southern District of Florida dismissed his lawsuit for lack of standing. The court concluded that he failed to show that his injury was traceable to the defendants' actions or that a favorable ruling would redress his injuries. The court also determined that he lacked standing under the treaty's rule of specialty provision because the United States had waived its right to object to the additional prosecutions, and his rights under the treaty were derivative of the United States' rights.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiff failed to establish Article III standing because his injury was not fairly traceable to the defendants' actions, as the decision to prosecute him was made independently by Panamanian officials. Additionally, the court found that a favorable declaratory judgment would not redress his injury, as it would not bind the Panamanian officials to drop the prosecutions. The court also concluded that the plaintiff lacked standing under the rule of specialty because the United States had consented to the prosecutions, extinguishing his derivative rights under the treaty. View "Berrocal v. Attorney General of the United States" on Justia Law

Thomas Clark, an inmate at Lebanon Correctional Institution (LCI), sought a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (DRC) to provide records under Ohio’s Public Records Act, R.C. 149.43. Clark also requested $6,000 in statutory damages for six public-records requests he claimed were either denied or ignored by DRC. The requests were made between October 2020 and March 2024, during his incarceration at North Central Correctional Complex (NCCC) and LCI.Clark alleged that he made multiple requests for records, including theft/loss reports and an inmate handbook from NCCC, and chow-hall menus and mail policies from LCI. He claimed that these requests were either ignored or denied. However, Clark did not provide copies of his 2020 and 2021 requests from NCCC, relying instead on a 2024 kite requesting copies of earlier kites. For the LCI requests, Clark provided evidence of his requests for chow-hall menus and mail policies.The Supreme Court of Ohio reviewed the case. The court found that Clark failed to prove he sent the 2020 and 2021 requests to NCCC. Regarding the LCI requests, the court noted that Clark did not direct his requests to the appropriate public-information officer, Ellen Myers, as required by DRC’s protocol. The court held that it is not a violation of the Public Records Act when an employee not responsible for public-records requests directs the requester to the proper office or person responsible for the records.The court denied Clark’s writ of mandamus, as well as his requests for statutory damages and court costs, concluding that Clark did not show a violation of the Public Records Act by DRC. View "State ex rel. Clark v. Ohio Dept. of Rehab. & Corr." on Justia Law

Several hundred children in Benton Harbor, Michigan, suffered from elevated lead levels in their blood after drinking lead-contaminated water from the city’s public water system for three years. Plaintiffs, represented by their guardians, filed a lawsuit against various state and city officials, as well as two engineering firms, alleging that these parties failed to mitigate the lead-water crisis and misled the public about the dangers of the drinking water. The claims included substantive-due-process and state-created-danger claims under 42 U.S.C. § 1983, as well as state-law negligence claims.The U.S. District Court for the Western District of Michigan dismissed the complaint in full. The court found that the plaintiffs did not plausibly allege a violation of their constitutional rights and declined to exercise supplemental jurisdiction over the state-law claims. Plaintiffs appealed the dismissal of their federal claims against the city and state officials and the state-law claims against one of the engineering firms.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the dismissal of the claims against the state officials, finding that the plaintiffs did not plausibly allege that these officials acted with deliberate indifference. However, the court reversed the dismissal of the claims against the city officials and the City of Benton Harbor, finding that the plaintiffs plausibly alleged that these officials misled the public about the safety of the water, thereby causing the plaintiffs to drink contaminated water. The court also reversed the district court’s declination of supplemental jurisdiction over the state-law claims against the engineering firm and remanded the case for further proceedings. The court affirmed the district court’s denial of leave to amend the complaint. View "Mitchell v. City of Benton Harbor" on Justia Law

Stefan Green, a South African citizen, applied for an R-1 visa to serve as a worship leader at Calvary Albuquerque, Inc., a non-profit church in New Mexico. His application was denied by a consular officer, leading Calvary to sue, alleging the denial violated the Religious Freedom Restoration Act (RFRA). The district court dismissed the suit, citing the consular nonreviewability doctrine, which generally prevents judicial review of consular officers' visa decisions.The United States District Court for the District of New Mexico dismissed the case, ruling that RFRA did not authorize judicial review of the consular officer’s decision. The court also found that the consular officer provided a facially legitimate and bona fide reason for the visa denial, and Calvary did not plausibly allege bad faith. The district court denied Calvary’s motion for a preliminary injunction.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s dismissal. The Tenth Circuit held that RFRA does not expressly authorize judicial review of consular officers' visa decisions, thus upholding the consular nonreviewability doctrine. The court also concluded that even if RFRA claims could be considered under the constitutional claim exception, the consular officer provided a facially legitimate and bona fide reason for denying the visa, and Calvary did not plausibly allege bad faith. Consequently, the court affirmed the district court’s judgment. View "Calvary Albuquerque v. Blinken" on Justia Law