Justia Government & Administrative Law Opinion Summaries

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

The case involves the Citizen Action Defense Fund (Fund) requesting the initial offers for collective bargaining agreements (CBAs) from the Washington State Office of Financial Management (OFM) under the Public Records Act (PRA). The key issue is whether the deliberative process exemption under RCW 42.56.280 applies to these initial offers after the tentative CBAs have been signed by the parties and submitted to the OFM director but before they are signed by the governor or funded by the legislature.The Thurston County Superior Court found that OFM violated the PRA by withholding the records, ruling that the deliberative process exemption did not apply once the CBAs were signed by the state’s negotiation representative and the union. The Court of Appeals reversed this decision, holding that the records were still exempt because the CBAs had not been presented to the governor for approval or funded by the legislature, and thus were not yet final.The Supreme Court of the State of Washington reviewed the case and affirmed the Court of Appeals' decision. The court held that the deliberative process exemption continues to apply until the legislature has funded the CBAs. The court reasoned that the collective bargaining process is not complete until the final step in the statutorily required implementation process, which is the approval of funding by the legislature. Therefore, the deliberative process exemption protects the documents related to collective bargaining until the CBAs are funded by the legislature. View "Citizen Action Def. Fund v. Off. of Fin. Mgmt." on Justia Law

Following Hurricane Ida in 2021, Terrebonne Parish requested assistance from Lafayette Utilities Systems (LUS) to help restore power in Houma, Louisiana. LUS, in turn, requested help from the City of Wilson, North Carolina. Agreements were signed to facilitate emergency assistance, and the City of Wilson dispatched employees to Louisiana. Due to a shortage of hotels in Houma, the employees stayed in Lafayette and commuted daily. Kevin Worrell, a City of Wilson employee, was involved in a vehicle collision while driving from Houma to Lafayette, resulting in injuries to Edward and Linda Breaux and Jessie and Vickie Blanchard.The plaintiffs filed separate negligence lawsuits in Louisiana state court, which were removed to the federal district court in the Western District of Louisiana. The cases were consolidated, and the defendants moved for summary judgment, asserting immunity under the Louisiana Homeland Security and Emergency Assistance and Disaster Act. The district court granted summary judgment, finding statutory immunity, and dismissed the plaintiffs' claims with prejudice. The plaintiffs appealed, challenging the district court's interpretation of the Act's immunity provision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted the need to interpret the Louisiana emergency preparedness law and expressed doubt about its ability to make a reliable Erie guess. Consequently, the court certified two questions to the Louisiana Supreme Court: (1) whether an employee of a city from another state working under an emergency assistance agreement is a "representative" of Louisiana or its political subdivisions, and (2) whether an individual providing emergency assistance is "engaging in emergency preparedness and recovery activities" while commuting from the recovery site to lodging. The Fifth Circuit will resolve the case based on the Louisiana Supreme Court's guidance. View "Breaux v. Worrell" on Justia Law

The case involves a challenge to Michigan's newborn screening program, which collects blood samples from newborns to test for diseases. The plaintiffs, consisting of parents and their children, argue that the program's retention and use of these blood samples without consent violate their Fourth and Fourteenth Amendment rights. The plaintiffs claim that the state's actions constitute a coercive, non-consensual taking and keeping of baby blood for the state's profit.Initially, the United States District Court for the Eastern District of Michigan dismissed the plaintiffs' complaint. However, a prior panel of the United States Court of Appeals for the Sixth Circuit reversed and remanded several claims, allowing the plaintiffs to pursue their Fourth and Fourteenth Amendment claims for injunctive and declaratory relief. On remand, the district court granted judgment in favor of the plaintiffs on nearly all their remaining claims and ordered the defendants to return or destroy the stored blood spots and data.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's judgment. The appellate court held that the defendants' actions of storing and using the blood spots and data did not violate the plaintiffs' Fourteenth Amendment substantive-due-process rights, as these actions did not constitute medical care or intrude on the parents' right to direct their children's medical care. Additionally, the court found that the plaintiffs failed to prove a possessory interest in the blood spots and data, which is necessary to establish a Fourth Amendment seizure claim. Consequently, the appellate court vacated the injunction requiring the defendants to destroy the stored data. View "Kanuszewski v. Michigan Dep't of Health & Human Services" on Justia Law

Petitioners sought to validate a portion of West Fork Pine Creek Road in Shoshone County, Idaho, which runs across private property and into public land managed by the Bureau of Land Management. The road is used by recreationalists to access an area known as "the Roller Coaster." Following disputes between local landowners and recreationalists, a petition was filed with the Shoshone County Board of Commissioners to validate the road. The Board denied the petition, citing concerns about environmental impacts, safety, and costs to taxpayers.The petitioners then sought judicial review in the District Court of the First Judicial District of Idaho, arguing that the Board erred in its decision. The district court affirmed the Board's decision, concluding that the Board's findings were supported by substantial and competent evidence. The petitioners appealed to the Supreme Court of Idaho, arguing that the district court erred in affirming the Board's conclusions.The Supreme Court of Idaho reviewed the case and determined that the Board erred in concluding that the 1909 meeting minutes did not establish the road as a public highway. However, the Court found no error in the Board's determination that validating the road was not in the public interest. The Court noted that the Board had considered various factors, including the availability of alternative access routes, the costs of surveying and maintaining the road, and the concerns of private property owners.Ultimately, the Supreme Court of Idaho affirmed the district court's decision, holding that while the road was established as a public highway in 1909, the Board did not abuse its discretion in determining that validation was not in the public interest. Neither party was awarded attorney fees on appeal. View "Jutila v. County of Shoshone" on Justia Law

The case involves a dispute between the Wisconsin State Legislature and the Wisconsin Department of Public Instruction (DPI) regarding the governor's partial veto power and the allocation of funds for literacy programs. The legislature argued that the governor exceeded his constitutional authority by partially vetoing a bill that was not an appropriation bill. DPI and the governor contended that the legislature's Joint Committee on Finance (JCF) improperly withheld funds appropriated for DPI's literacy programs.The Dane County Circuit Court granted summary judgment in part for each party. The court concluded that the governor did not exceed his constitutional boundaries in partially vetoing the bill and that JCF did not improperly withhold funds from DPI. The court reasoned that the bill in question was an appropriation bill and that the governor's partial veto was valid. However, the court also held that DPI was not entitled to the funds appropriated to JCF.The Wisconsin Supreme Court reviewed the case and held that the governor breached his constitutional boundaries because the bill he partially vetoed was not an appropriation bill. The court reaffirmed the "four corners rule," which requires that an appropriation bill must set aside public funds for a public purpose within its text. The court concluded that the bill in question did not meet this requirement and, therefore, was not subject to the governor's partial veto authority. The court also held that JCF did not improperly withhold funds from DPI, as the funds were lawfully appropriated to JCF. Consequently, the court affirmed in part and reversed in part the circuit court's summary judgment order. View "Wisconsin State Legislature v. Wisconsin Department of Public Instruction" on Justia Law

Petitioners, including various agricultural and trade organizations, challenged the Environmental Protection Agency (EPA) over a rule that set an equation for calculating vehicle fuel economy, specifically the "Ra factor." They argued that the Ra factor was set arbitrarily low, which effectively increased federal fuel economy standards and decreased demand for gasoline, harming their businesses.The case was reviewed by the United States Court of Appeals for the Fifth Circuit. The petitioners contended that the EPA's rule violated the Administrative Procedure Act (APA) by ignoring significant comments and data that flagged flaws in the determination of the Ra factor. They pointed out that the EPA's test program used too few and outdated vehicles, included data from a malfunctioning vehicle, and excluded data from a properly functioning one. Additionally, they argued that the EPA failed to consider alternative data sources, such as manufacturer certification data, which showed a higher Ra factor.The Fifth Circuit found that the EPA's rule was arbitrary and capricious. The court noted that the EPA did not adequately respond to significant comments that raised substantial issues with the test program's sample size, the representativeness of the vehicles tested, and the inclusion and exclusion of certain test data. The court also found that the EPA failed to justify its rejection of alternative data sources. As a result, the court held that the EPA did not demonstrate that its decision was the product of reasoned decision-making.The court granted the petition for review and vacated the portion of the EPA's rule that set and implemented the Ra factor of 0.81. The court concluded that there was no serious possibility that the EPA could substantiate its decision on remand, and thus, vacatur was the appropriate remedy. View "Texas Corn Producers v. EPA" on Justia Law

Kris Hawkins filed a Realty Transfer Certificate in March 2018, indicating that a property in Florence, Ravalli County, had been transferred to the Olson Trust. The Department of Revenue (DOR) requested documentation identifying the trustee of the Trust in April 2018 and January 2019, but it was never provided. In July 2023, Hawkins, claiming to be the trustee, requested an informal review of the DOR’s appraised value of the property, which was not adjusted. Hawkins appealed to the Ravalli County Tax Appeals Board, but there was doubt about her status as trustee. Despite several requests, Hawkins did not provide the necessary documentation.The Ravalli County Tax Appeals Board denied Hawkins’s request for a reduction in value, and she appealed to the Montana Tax Appeal Board (MTAB). MTAB requested confirmation of Hawkins’s role as trustee multiple times. Hawkins filed a declaration for disqualification of MTAB members, alleging bias, but it was unsupported. She also filed a petition for interlocutory adjudication with the District Court, which was struck because the Trust was not represented by an attorney. Hawkins then requested to substitute herself for the Trust and reinstate the petition. MTAB dismissed the appeal due to lack of documentation, and the District Court dismissed the petition for lack of subject matter jurisdiction.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision. The court held that the District Court lacked subject matter jurisdiction to hear an interlocutory adjudication because the underlying matter had already been dismissed by MTAB. The court found that Hawkins’s affidavit alleging bias was insufficient and that MTAB did not lose jurisdiction after the unfounded declaration. The District Court’s dismissal of the petition was proper. View "Hawkins v. State" on Justia Law

A group called Idahoans United for Women and Families filed an original action in the Idaho Supreme Court seeking writs of certiorari and mandamus. They challenged the fiscal impact statement (FIS) and ballot titles prepared for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” The group argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their versions or order the Idaho Division of Financial Management (DFM) and the Attorney General to prepare new ones.The Idaho Supreme Court dismissed the petition against the Secretary of State, as Idahoans United failed to specify the writ or what they sought to compel. The court partially granted the writ of mandamus against DFM, finding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impact, unclear language, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, concluding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by a specified deadline. The court declined to certify the versions provided by Idahoans United and did not award attorney fees to any party. Upon submission, the court reviewed the new FIS and short ballot title, concluding that both substantially complied with the statutory requirements and certified the new short ballot title to the Idaho Secretary of State. View "Idahoans United for Women and Families v. Labrador" on Justia Law

Fred Hodara filed a lawsuit against the Oklahoma Department of Corrections (DOC) for alleged violations of the Open Records Act, seeking access to records related to the drugs used in executions. Initially, the DOC claimed it had no responsive records, but later provided some documents, albeit heavily redacted. Hodara sought declaratory and injunctive relief, arguing that the DOC's refusal to provide the requested material was unlawful. The DOC moved to dismiss the case, citing a statutory exemption under Title 22, Section 1015(B), which was later amended in 2024 to broaden the scope of confidentiality.The district court denied both parties' motions for summary judgment due to unresolved factual disputes. However, after the statutory amendment, the DOC filed a second motion to dismiss, which the court granted, concluding that the amended statute precluded Hodara's Open Records Act claim. Hodara appealed the dismissal, challenging the retroactive application and constitutionality of the amended statute.The Supreme Court of the State of Oklahoma reviewed the case de novo, focusing on the October 4, 2024, order. The court found that the 2024 amendment to Section 1015(B) did not create a new confidentiality privilege but clarified the existing one. The court held that the amendment could be applied retroactively and did not violate the Oklahoma Constitution. The court affirmed the district court's decision, concluding that the DOC's refusal to provide the requested records was lawful under the amended statute. View "HODARA v. OKLAHOMA DEPARTMENT OF CORRECTIONS" on Justia Law