Justia Government & Administrative Law Opinion Summaries

A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information.Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. The case was removed to the United States District Court for the Western District of Missouri. The superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of immunity de novo. The appellate court held that the current superintendent was a proper Ex parte Young defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity. View "Cunningham v. Olson" on Justia Law

A man traveling with his family, including his thirteen-year-old daughter, on Delta Air Lines was reported by a flight attendant for suspected human trafficking or sexual abuse after comforting his distressed daughter during turbulence. The flight attendant relayed her suspicions to the flight captain, who then involved the airport station manager, resulting in a call to law enforcement. Upon landing, police detained and questioned the man and his daughter but found no probable cause for arrest. The incident caused the man significant emotional distress and exacerbated his pre-existing PTSD.He subsequently filed a lawsuit in the Circuit Court of the City of Newport News against the flight attendant, Delta, and Endeavor Air, alleging negligence, intentional infliction of emotional distress, tortious interference with parental rights, and false imprisonment. The defendants removed the case to the United States District Court for the Eastern District of Virginia and moved to dismiss, claiming immunity under Virginia Code § 63.2-1512. The district court agreed, holding that the defendants were immune because the report, even if made only to law enforcement and not to social services, was made in good faith and without malicious intent. The man appealed, and the United States Court of Appeals for the Fourth Circuit was uncertain whether the immunity statute applied in this context and certified the legal question to the Supreme Court of Virginia.The Supreme Court of Virginia, upon review of the certified question, held that Virginia Code § 63.2-1512 does not provide immunity to a nonmandatory reporter who, in good faith, reports suspected child abuse to law enforcement without also contacting a Department of Social Services employee or the designated hotline. The Court reasoned that the statutory language is clear and limits immunity to specific categories, which do not include complaints made solely to law enforcement by nonmandatory reporters. The answer to the certified question was “no.” View "Cupp v. Delta Air Lines, Inc." on Justia Law

Americare Healthcare Services, Inc., a third-party home care provider in Ohio, and its owner, Dilli Adhikari, hired live-in workers—most of whom cared for their own family members—to provide services to elderly or disabled clients. Between October 2018 and October 2021, Americare failed to pay overtime wages to these employees, claiming entitlement to exemptions under the Fair Labor Standards Act (FLSA): the “Companionship Services Exemption” and the “Live-In Exemption.” The Department of Labor, however, had promulgated a 2013 regulation that prohibited third-party employers from relying on these exemptions.The United States District Court for the Southern District of Ohio granted summary judgment to the Department of Labor, finding Americare and Adhikari liable for willful violations of the FLSA’s overtime requirements. The district court further held that the 2013 Third-Party Regulation was valid, and that Americare and Adhikari lacked standing to challenge a related regulatory definition that narrowed the scope of “companionship services.” Americare and Adhikari appealed only the district court’s rulings on the regulation’s validity and their lack of standing.The United States Court of Appeals for the Sixth Circuit reviewed the case, applying the framework for agency rulemaking authority post-Loper Bright Enterprises v. Raimondo. The Sixth Circuit held that the FLSA’s express statutory delegation allowed the Department of Labor to define and delimit the applicability of the companionship and live-in exemptions, including excluding third-party employers from their reach. The court further held that Americare and Adhikari lacked standing to challenge the definition of companionship services because the bar to their use of the exemption arose from the third-party regulation, not from the definition itself. The judgment of the district court was therefore affirmed. View "Department of Labor v. Americare Healthcare Services" on Justia Law

A United States citizen originally from Yemen filed family-based visa petitions (Form I-130) in 2002 on behalf of several relatives, including his stepdaughter. The immigration authorities sent a notice of intent to deny these petitions and a subsequent denial letter to the address provided on the petition. The petitioner did not respond, and the petitions were denied. Twenty years later, the petitioner sued, asserting that he never received the notices because the agency had mistakenly sent them to an address where he did not live, and that this lack of notice violated the Due Process Clause and the Administrative Procedure Act. He attached a redacted version of his petition to his complaint, omitting the address at issue.The United States District Court for the Northern District of Illinois, Eastern Division, initially denied the government’s motion to dismiss, finding that the complaint plausibly supported the application of the discovery rule or equitable tolling and otherwise stated a claim. However, when the government moved for judgment on the pleadings and submitted an unredacted copy of the I-130 petition showing that the petitioner himself had listed the very address to which the notices were sent, the court found this document dispositive. The petitioner did not meaningfully contest the authenticity or content of the unredacted petition, failed to appear at the hearing, and did not object to the government’s supporting affidavit.On appeal, the United States Court of Appeals for the Seventh Circuit held that the unredacted I-130 petition conclusively refuted the petitioner’s factual claims. The court held that when a plaintiff’s own incorporated documents contradict the complaint’s allegations, those documents control. The court affirmed the district court’s entry of judgment for the government, finding that the due process and APA claims failed as a matter of law. View "Muthana v Mullin" on Justia Law

The case concerns significant changes made by the U.S. Department of Housing and Urban Development (HUD) to the Continuum of Care (CoC) program, which provides federal funding for homeless assistance projects. In November 2025, HUD issued a new Notice of Funding Opportunity (NOFO) that rescinded a previously issued two-year NOFO and introduced new requirements, including a drastic reduction in renewal funding for core permanent housing projects and new eligibility conditions. These changes threatened to eliminate funding for many projects, risking increased homelessness in the affected communities. Two groups of plaintiffs, including states, cities, and advocacy organizations, challenged HUD’s actions, alleging violations of the Administrative Procedure Act (APA) and constitutional provisions.The United States District Court for the District of Rhode Island issued preliminary injunctions prohibiting HUD from rescinding the prior NOFO and from implementing the challenged conditions in the new NOFOs. The court found that HUD’s actions likely violated the APA, were arbitrary and capricious, and would cause irreparable harm by creating funding gaps and service disruptions for vulnerable populations. After Congress passed new appropriations legislation in early 2026—setting a structure for grant renewals to avoid funding gaps—HUD moved to dissolve the injunctions, arguing that the legislative changes eliminated any ongoing harm and affected the merits of the legal claims. The district court denied the motion, concluding that the risk of harm persisted and that the plaintiffs remained likely to succeed on their claims.On appeal, the United States Court of Appeals for the First Circuit reviewed only the district court’s denial of HUD’s motion to dissolve the preliminary injunctions. The court held that HUD failed to make a strong showing that the intervening appropriations law eliminated the plaintiffs’ risk of harm or undermined the basis for the injunctions. The First Circuit therefore denied HUD’s request for a stay pending appeal. View "National Alliance to End Homelessness v. Department of Housing and Urban Development" on Justia Law

During the summer of 2025, protests erupted in Southern California in response to federal immigration raids. Protesters, legal observers, and journalists alleged that officers of the Department of Homeland Security (DHS), including agents from Immigration and Customs Enforcement, the Federal Protective Services, and Customs and Border Protection, used crowd control weapons indiscriminately against them. Multiple individuals, including members of the press and protesters, suffered significant physical injuries during these events, even when they were complying with police orders or were not near disruptive protest activity.Several individual journalists, legal observers, protesters, and two press organizations filed suit in the United States District Court for the Central District of California. They alleged violations of their First Amendment rights, specifically the right to be free from retaliation for engaging in protected activities and the right of public access to protests. The district court issued a preliminary injunction to protect the rights of protesters, journalists, and legal observers, finding that the defendants’ conduct chilled First Amendment activity. The government appealed, arguing that the injunction was overly broad and legally unsound.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision. The Ninth Circuit held that the plaintiffs were likely to succeed on their First Amendment retaliation claims, that both individual and organizational plaintiffs had standing, and that the other requirements for a preliminary injunction were met. However, the court found that the scope of the injunction was overbroad because it extended relief to non-parties and included provisions not narrowly tailored to the specific harms alleged. The Ninth Circuit affirmed the district court’s decision to issue a preliminary injunction but vacated and remanded the case for the district court to craft a narrower injunction consistent with its opinion. View "LOS ANGELES PRESS CLUB V. NOEM" on Justia Law

This case concerns requests made by two media organizations to the Colorado Department of Human Services (CDHS) for information about the number of child abuse or neglect reports made from three state-funded residential child care facilities (RCCFs) over a three-year period, and how many were screened for investigation. CDHS denied the requests, asserting that providing the facility-specific numbers would violate the confidentiality provisions of the Colorado Children's Code Records and Information Act, specifically section 19-1-307(1)(a), which protects the name, address, and other identifying information of any child, family, or informant in such reports. The media organizations declined CDHS's offer to provide aggregate numbers for all three facilities combined and sued for disclosure of the per-facility data under the Colorado Open Records Act (CORA).The Denver District Court agreed with CDHS, holding that subsection (1)(a) barred disclosure of the requested information, as it would necessarily identify the addresses involved in the reports. On appeal, a divided panel of the Colorado Court of Appeals found the statute ambiguous and, after considering legislative history and potential constitutional issues, determined that only information that constitutes "identifying information" is protected. The appellate court remanded the case to the district court to determine if the requested disclosures would reveal identifying information.On review, the Supreme Court of Colorado held that section 19-1-307(1)(a) is unambiguous and extends confidentiality to all names and addresses of children, families, or informants in reports of child abuse or neglect, as well as any other identifying information. However, the court found that CDHS failed to demonstrate that disclosing the requested six numbers would reveal protected information, as the RCCFs' addresses are already public. The Supreme Court reversed the judgment of the Court of Appeals and ordered disclosure of the six numbers. View "Brubaker v. Colo. Sun & Tegna" on Justia Law

The Montana legislature enacted a law, HB 937, and associated administrative rules that imposed new licensure and regulatory requirements specifically on abortion clinics, which were defined as facilities providing abortion-inducing drugs or performing surgical abortions to at least five patients per year. These requirements did not apply to clinics that provided identical medications and procedures exclusively for miscarriage management. Plaintiffs, including two clinics and a nurse practitioner, challenged the law and rules, arguing that they violated the equal protection and privacy rights guaranteed by the Montana Constitution. They asserted that these new requirements could force them to cease providing abortion care, thereby restricting their patients’ access to such services.After the plaintiffs filed their complaint, the First Judicial District Court, Lewis and Clark County, initially granted a temporary restraining order and later a preliminary injunction, preventing enforcement of HB 937 and the associated rules. The District Court found that the plaintiffs were likely to succeed on their equal protection claim, that irreparable harm was likely absent an injunction, that the balance of equities favored the plaintiffs, and that an injunction was in the public interest. The court determined that the law treated similarly situated providers—those giving identical care for either miscarriage or abortion—differently solely based on the purpose of the treatment. The court applied strict scrutiny, finding that the state had not demonstrated a compelling interest or that the law was narrowly tailored.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s preliminary injunction. The Supreme Court held that HB 937 and the rules likely violate the Montana Constitution’s guarantee of equal protection by subjecting abortion providers to unique, burdensome licensing requirements not imposed on providers of identical miscarriage care, thus likely infringing on the fundamental right to privacy. The Court concluded that the plaintiffs met all four elements required for a preliminary injunction and affirmed the lower court’s order in its entirety. View "All Families v. State" on Justia Law

A group of pharmaceutical manufacturers that participate in the federal 340B drug pricing program challenged a new West Virginia law, S.B. 325, which imposed restrictions and penalties on manufacturers regarding the delivery of discounted drugs to contract pharmacies. The 340B program is a federal scheme where drug manufacturers provide discounts to designated health care providers (“covered entities”) in exchange for access to the Medicaid market. Dissatisfied with the federal program’s scope, West Virginia enacted S.B. 325, which specifically barred manufacturers from restricting delivery of 340B drugs to any location authorized by a covered entity (including contract pharmacies), and from requiring data submission as a condition for delivery, with significant penalties for violations.The manufacturers sued in the United States District Court for the Southern District of West Virginia seeking to enjoin enforcement of S.B. 325, arguing that it was preempted by federal law. The district court found that the manufacturers were likely to succeed on the merits of their preemption claim, that they faced irreparable harm, and that the balance of equities and public interest favored injunctive relief. The court granted a preliminary injunction against enforcement of the statute.On appeal, the United States Court of Appeals for the Fourth Circuit addressed whether S.B. 325 was preempted by federal law. The Fourth Circuit held that S.B. 325 likely interferes with the federal 340B program by imposing additional conditions on manufacturers solely because of their participation in a federal program, thereby intruding into a domain reserved for federal regulation. The court found that Congress had struck a careful bargain in the 340B program and that West Virginia’s law sought to alter that bargain in a way that conflicted with federal objectives and the enforcement scheme administered by the Department of Health and Human Services. The Fourth Circuit affirmed the district court’s preliminary injunction, barring enforcement of S.B. 325. View "Pharmaceutical Research & Manufacturers of America v. McCuskey" on Justia Law

A trade association representing the majority of the world’s liner shipping services challenged a rule issued by the Federal Maritime Commission. Under recent amendments to the Shipping Act, Congress directed the Commission to define what constitutes an “unreasonable refusal to deal or negotiate” by ocean common carriers regarding vessel space accommodations. The Commission responded by adopting a rule specifying non-binding factors for evaluating unreasonable refusals, including whether a carrier quoted rates vastly above market value, required carriers to submit an annual “documented export policy,” and removed explicit reference to “business decisions” from its list of factors. The association objected, arguing that the rule exceeded the Commission’s authority and was arbitrary and capricious.After the Commission published its final rule, the association filed a petition for review in the United States Court of Appeals for the District of Columbia Circuit. The association claimed that the Commission lacked authority to consider price in its analysis, that the requirement for a documented export policy was ultra vires and arbitrary, and that removal of the “business decisions” factor was likewise arbitrary. The Commission defended the rule’s approach, asserting its statutory power to require reports and to evaluate factors relevant to reasonableness.The United States Court of Appeals for the District of Columbia Circuit denied the petition for review. The court held that the Commission’s consideration of price as an indicator of unreasonable refusal did not amount to unauthorized rate regulation, and that the requirement for a documented export policy was within the Commission’s statutory authority. The court also found that the omission of “business decisions” as a listed factor did not preclude their consideration in individual cases. The court concluded that the rule was neither beyond the Commission’s statutory authority nor arbitrary and capricious. View "World Shipping Council v. FMC" on Justia Law