Justia Government & Administrative Law Opinion Summaries

Two inmates in Virginia, each serving sentences for attempted aggravated murder, were initially informed by the Department of Corrections that they would be released in July 2022 due to a new state law expanding sentence credits for good behavior. This law, H.B. 5148, allowed certain inmates to earn more credits and thus reduce their incarceration time. However, after a change in the Attorney General’s office, the new Attorney General issued an advisory opinion stating that inmates convicted of inchoate offenses related to aggravated murder were not eligible for the enhanced credits. As a result, the Department reversed its earlier decision and kept the inmates incarcerated for an additional year, until the Supreme Court of Virginia later clarified that such inmates were indeed eligible for the credits and ordered their release.The inmates then filed a lawsuit in the United States District Court for the Eastern District of Virginia, seeking damages under 42 U.S.C. § 1983. They alleged that the Attorney General and the Director of Corrections violated their Eighth and Fourteenth Amendment rights by acting with deliberate indifference to their over-incarceration. The district court dismissed the complaint, finding that both officials had acted reasonably in interpreting an unsettled question of state law and that their conduct did not rise to the level of deliberate indifference or conscience-shocking behavior.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the officials’ actions did not constitute deliberate indifference under the Eighth Amendment, nor did they shock the conscience under the Fourteenth Amendment. The court emphasized that federal courts should not hold state officials personally liable for reasonable legal interpretations of unsettled state law, especially when those interpretations are made in good faith and with conventional legal reasoning. View "Swart v. Miyares" on Justia Law

Causam Enterprises, Inc. owns several patents related to “demand response” technology, which allows electrical utilities to reduce power demand in response to certain conditions. Causam filed a complaint with the United States International Trade Commission (ITC), alleging that Resideo Smart Homes Technology (Tianjin) and its affiliate Ademco, Inc. were importing and selling internet-connected smart thermostats that infringed method claim 1 of U.S. Patent No. 10,394,268, which Causam claimed to own. Causam sought to exclude these products from importation. During the ITC investigation, respondents argued that Causam did not own the patent and that Resideo’s products did not infringe the asserted claims.The assigned administrative law judge (ALJ) at the ITC found that Causam did not own the ’268 patent and that Resideo’s products did not infringe the claims. The full Commission, upon review, adopted only the noninfringement finding and did not address the ownership issue. Causam appealed to the United States Court of Appeals for the Federal Circuit, challenging the noninfringement determination and seeking a ruling on ownership. Meanwhile, the Patent Trial and Appeal Board (PTAB) held, in a separate inter partes review, that claim 1 of the ’268 patent was unpatentable, and the Federal Circuit affirmed that decision in a companion case.The United States Court of Appeals for the Federal Circuit held that Causam owns the ’268 patent, interpreting the relevant assignment agreements to exclude continuations-in-part from a prior assignment, thus leaving ownership with Causam. However, the court did not reach the noninfringement issue because its affirmance of the PTAB’s finding that claim 1 is unpatentable rendered the appeal moot. The court therefore dismissed the appeal as moot. View "CAUSAM ENTERPRISES, INC. v. ITC " on Justia Law

Nathan Gault was a party to a divorce action in the Medina County Court of Common Pleas. After the case concluded, the clerk charged him various fees, including a “Clerk Computer Operation” fee. Gault believed he had been overcharged, specifically challenging the additional dollar per page fee assessed for making a complete record of the proceedings. He filed a class-action complaint against the clerk, the county treasurer, and the county itself, alleging that the clerk charged him $125 in computer-operation fees, which was over $100 more than statutorily authorized.The Medina County Court of Common Pleas initially granted judgment on the pleadings for the defendants, finding Gault’s claim barred by res judicata. The Ninth District Court of Appeals reversed, holding that res judicata did not apply because the total amount owed and the methodology for determining the fees were not ascertainable from the final judgment in the divorce action, and the defendants were not parties to the prior proceedings. On remand, the trial court again ruled for the defendants, interpreting the statutes to permit the clerk to charge two dollars per page—one dollar under R.C. 2303.20(H) and an additional dollar under former R.C. 2303.201(B)(1). The Ninth District reversed, concluding that only one additional dollar total could be charged for the service, not one dollar per page.The Supreme Court of Ohio reviewed the case, consolidating a discretionary appeal and a certified conflict. The court held that, under the plain text of former R.C. 2303.201(B)(1), the clerk may charge only one additional dollar total for making a complete record under R.C. 2303.20(H), regardless of the number of pages. The Supreme Court of Ohio affirmed the judgment of the Ninth District Court of Appeals. View "State ex rel. Gault v. Medina Cty. Court of Common Pleas Clerk" on Justia Law

After their property in DeKalb County was annexed by the City of Atlanta, two parents sought to enroll their children in Atlanta Public Schools (APS). APS, however, denied enrollment, citing a 2021 Georgia law (SB 209) that prevents the expansion of APS boundaries to include newly annexed areas unless specifically authorized. The City of Atlanta had approved the annexation and expressed its intent for the APS boundaries to expand accordingly, but APS maintained that SB 209 prohibited such an extension.The parents and the City of Atlanta filed a petition for declaratory and injunctive relief against the State of Georgia, arguing that SB 209 was unconstitutional under the Georgia Constitution’s Single Subject Rule. The case was initially filed in Fulton County, transferred to DeKalb County, and then refiled in Fulton County against the State after the plaintiffs voluntarily dismissed the DeKalb action. The DeKalb County School District (DCSD) was allowed to intervene as a plaintiff. The trial court denied motions to dismiss, found that the plaintiffs had standing, determined there was a justiciable controversy, and ruled that SB 209 violated the Single Subject Rule, granting declaratory and injunctive relief to the plaintiffs.On appeal, the Supreme Court of Georgia reviewed whether the trial court had jurisdiction to grant relief. The Supreme Court of Georgia held that the plaintiffs failed to establish an actual or justiciable controversy with the State, as the alleged harm stemmed from APS’s actions, not from any enforcement by the State. Because the dispute did not involve the parties before the court, the Supreme Court of Georgia vacated the trial court’s judgment and remanded the case with instructions to dismiss the petition. View "PILATO v. STATE OF GEORGIA" on Justia Law

Owners of developed commercial and residential properties in Athens-Clarke County challenged the county’s stormwater utility charge, arguing that it was an unconstitutional tax rather than a fee. The charge, established by county ordinances in 2004, funds stormwater management services required by federal law, with the amount assessed based on impervious surface area and land-use classification. The ordinance exempts certain properties, such as public roads and sidewalks, and offers credits for on-site stormwater management. The funds collected are used for flood prevention, pollution minimization, and compliance with federal regulations.Previously, the Superior Court of Athens-Clarke County granted summary judgment to the county, finding that the stormwater utility charge was a fee, not a tax, and thus not subject to the Georgia Constitution’s taxation uniformity provision. This decision relied on the Georgia Supreme Court’s earlier ruling in Homewood Village, LLC v. Unified Government of Athens-Clarke County, which had addressed the same ordinance and held it imposed a fee rather than a tax. The appellants also pursued related claims in federal court, but those were dismissed on abstention grounds.On appeal, the Supreme Court of Georgia affirmed the trial court’s decision. The court held that its prior decision in Homewood Village, LLC v. Unified Government of Athens-Clarke County controlled, reaffirming that the stormwater utility charge is a fee and not a tax, and therefore the uniformity provision does not apply. The court also rejected the appellants’ arguments that the charge constituted an unconstitutional taking under the Georgia and United States Constitutions, finding no basis for such a claim. Finally, the court found that the trial court had properly applied the summary judgment standard and had not improperly resolved factual disputes. The judgment in favor of the county was affirmed. View "HOMEWOOD ASSOCIATES INC. v. UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY" on Justia Law

An inmate in Missouri, facing imminent execution, requested that his two daughters—both ordained ministers—be allowed to serve as his spiritual advisors in the execution chamber. One daughter would administer communion and anoint him with oil, then move to the viewing area, while the other would enter the chamber to pray over and touch him during the execution. The Missouri Department of Corrections denied this request, citing security concerns, but offered alternatives: a non-relative spiritual advisor, prison clergy, or his attorney could perform the rituals, with his daughters directing the proceedings from behind glass.After exhausting administrative remedies and just five days before his scheduled execution, the inmate filed suit in the United States District Court for the Eastern District of Missouri. He alleged that the Department’s refusal violated his rights under the First Amendment’s Free Exercise Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA). He sought a preliminary injunction and a stay of execution. The district court denied his requests and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of a stay of execution. The court focused on whether the inmate had shown a likelihood of success on the merits, specifically whether the Department’s policy imposed a “substantial burden” on his religious exercise under RLUIPA. The court found that, while the inmate preferred his daughters as spiritual advisors, he did not demonstrate that only they could perform the rituals in accordance with his beliefs. The court concluded that the Department’s alternatives did not significantly inhibit his religious exercise and that security concerns justified the restriction. The Eighth Circuit denied the motion for a stay of execution. View "Shockley v. Adams" on Justia Law

A firefighter with fifteen years of service applied for disability pension benefits from a municipal pension fund, claiming he was permanently disabled due to post-traumatic stress disorder (PTSD) resulting from several traumatic events encountered during his career. The pension fund’s Board of Trustees denied his application after a hearing, finding he did not meet the policy’s requirements for a mental health disability benefit, specifically the requirement that the traumatic events causing the disability be “unexpected” within the context of his regular duties.The applicant sought judicial review in the Chancery Court for Hamilton County, which reviewed the Board’s decision under Tennessee’s Uniform Administrative Procedures Act (UAPA). The trial court found the Board’s interpretation of the policy arbitrary and capricious, holding that the events were unexpected to the applicant and that the policy should be construed in favor of the employee. The trial court reversed the Board’s denial and awarded benefits. The Tennessee Court of Appeals affirmed, finding the policy ambiguous and applying a liberal construction doctrine to interpret the policy in favor of the applicant.On further appeal, the Supreme Court of Tennessee held that the term “unexpected” in the policy was not ambiguous and should be given its plain meaning. The Court concluded that the Board’s decision was supported by substantial and material evidence and was not arbitrary or capricious. The Court also held that the liberal construction doctrine did not apply because the policy was unambiguous. Accordingly, the Supreme Court of Tennessee reversed the judgments of the Court of Appeals and the trial court, reinstating the Board’s denial of disability benefits, and remanded the case for further proceedings consistent with its opinion. View "Long v. Chattanooga Fire and Police Pension Fund" on Justia Law

A longtime Alaska resident with extensive experience in personal-use and commercial fishing brought suit against the State of Alaska, alleging that the State’s management of chinook and chum salmon populations in the Yukon and Kuskokwim Rivers violated the sustained yield principle mandated by the Alaska Constitution. The plaintiff claimed that the significant decline in these salmon populations since statehood was evidence of unconstitutional management. He did not challenge any specific policy, regulation, or action, but instead sought a declaration that the State’s management had been unconstitutional for decades and requested injunctive relief to compel the State to fulfill its sustained yield obligations.The Superior Court for the Fourth Judicial District, Bethel, granted the State’s motion to dismiss for failure to state a claim. The court found that the claims presented nonjusticiable political questions reserved for the legislative branch, that the plaintiff failed to allege a concrete injury or identify specific State actions causing harm, and that deference to agency expertise was warranted in the absence of a challenge to a particular policy or action.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s dismissal. The Supreme Court held that the claims for injunctive relief were nonjusticiable because they would require the judiciary to make initial fisheries policy determinations, a function constitutionally committed to the legislative and executive branches. The Court further held that the claim for declaratory relief was not justiciable because it would not clarify or settle the legal relations between the parties, as it did not identify specific actions or policies to be addressed. The Court concluded that, absent a challenge to a particular State action or policy, the claims did not present an actual controversy suitable for judicial resolution. View "Forrer v. State of Alaska" on Justia Law

Several months before an election, complaints were filed with the Alaska Public Offices Commission alleging that two political groups, A Stronger Alaska and the Republican Governors Association, had violated Alaska’s campaign finance laws by coordinating with a gubernatorial campaign and failing to comply with disclosure requirements. The Commission initiated expedited proceedings, held hearings where officials from the groups testified, and then chose not to make a final determination on the alleged violations. Instead, the Commission remanded the matters to its staff for further investigation on a regular, non-expedited basis. The Commission’s staff subsequently issued administrative subpoenas seeking documents and communications from the groups, but the groups refused to comply.The Commission sought judicial enforcement of its subpoenas in the Superior Court for the State of Alaska, Third Judicial District. The groups opposed enforcement, arguing that the subpoenas were unnecessary because the Commission already had relevant testimony, that further investigation was barred by res judicata, and that the process violated their due process rights. They also challenged the constitutionality of the statutory scheme authorizing the expedited process. The superior court rejected all of these arguments, granted summary judgment in favor of the Commission, and ordered enforcement of the subpoenas.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s decision. The court held that the subpoenas were not unreasonable or oppressive simply because prior testimony had been given, as documentary evidence could still be relevant. The court also held that res judicata did not apply because the Commission had not issued a final decision on the merits, and that the process did not violate substantive due process or result in an absurd or unconstitutional statutory scheme. The court affirmed the order granting summary judgment to the Commission. View "Republican Governors Association v. Hebdon" on Justia Law

A firefighter employed by the City of Birmingham developed hypertension during his employment and applied to the City of Birmingham Retirement and Relief System for both extraordinary and ordinary disability benefits, arguing that his condition and the medications required to control it prevented him from safely performing his job. He detailed unsuccessful attempts to manage his hypertension with various medications and provided medical opinions supporting his claim that only beta-blockers, which are not recommended for firefighters, could control his blood pressure. The Board, after considering the opinion of its medical expert, denied both applications, concluding that he had not exhausted all other antihypertensive regimens.The firefighter sought review of the Board’s decisions by filing a petition for a writ of mandamus in the Jefferson Circuit Court, as permitted by statute. Initially, the circuit court dismissed the action for lack of service, but the Supreme Court of Alabama reversed that dismissal and remanded the case. After service was obtained, the respondents argued that the claim for extraordinary disability benefits failed as a matter of law because the hypertension was not caused by a specific workplace accident, and that the Board’s denial of ordinary disability benefits was not manifestly wrong. The circuit court denied the mandamus petition without a hearing or consideration of evidence beyond the pleadings.The Supreme Court of Alabama affirmed the circuit court’s denial of extraordinary disability benefits, holding that the statutory requirements were not met because the disability did not result from an accident at a definite time and place. However, the Supreme Court reversed the denial of ordinary disability benefits, finding that the circuit court erred by not allowing the petitioner to present evidence or reviewing the evidence considered by the Board. The case was remanded for further proceedings on the ordinary disability claim. View "Hoffman v. City of Birmingham Retirement and Relief System" on Justia Law