Justia Government & Administrative Law Opinion Summaries

Several members of the public requested records from the Seattle Police Department (SPD) regarding officers who attended the January 6, 2021, rally in Washington, DC. The officers involved filed a lawsuit to prevent the release of their identities, arguing that their identities should be exempt from disclosure based on statutory and constitutional privacy rights. They sought a preliminary injunction to prevent the release of their identities within those public records.The King County Superior Court denied the officers' motion for a preliminary injunction, determining that the officers failed to show that the information in the public records was likely exempt from disclosure. The court also denied the officers' motion to proceed under pseudonyms. The officers appealed, and the Court of Appeals reversed the denial of the preliminary injunction, concluding that the First Amendment prohibited the disclosure of the officers' identities. The Court of Appeals did not evaluate whether the disclosure would violate the officers' statutory right to privacy under the Public Records Act (PRA).The Supreme Court of the State of Washington reviewed the case and held that the officers did not demonstrate a likelihood of success on the merits that their identities were exempt based on either a statutory or constitutional right to privacy. The court concluded that the officers did not have a privacy interest in their identities as public employees who attended a highly publicized event. The court also held that the officers did not show a need to litigate under pseudonyms. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "John Does v. Seattle Police Dep't" on Justia Law

In February 2024, Cailin Leann Gackle was arrested for driving under the influence of alcohol. At the police department, Officer Cullen Hall conducted two breath test sequences using the Intoxilyzer 8000. The first test sequence was invalidated due to a "Difference Too Great" between the two samples. Officer Hall began the second test sequence 18 minutes after the first test ended, instead of the required 20 minutes. Gackle's driving privileges were suspended for 365 days based on the results of the second test.Gackle requested an administrative hearing, arguing that the breath test was not fairly administered because Officer Hall did not comply with the 20-minute waiting period required by the approved method. The hearing officer overruled her objection, admitted the test records, and upheld the suspension. Gackle appealed to the District Court of Ward County, which affirmed the Department of Transportation's decision.The North Dakota Supreme Court reviewed the case and concluded that the Department failed to establish the fair administration of the breath test. The court determined that the approved method requires a 20-minute wait before beginning a new test sequence after an invalid test. Since Officer Hall only waited 18 minutes, the test was not administered in accordance with the approved method. The court held that without expert testimony to address the deviation, the test results could not be considered reliable. Consequently, the court reversed the lower court's decision and remanded the case to the Department for reinstatement of Gackle's driving privileges. View "Gackle v. NDDOT" on Justia Law

The taxpayer, 480 McClellan LLC, leased property from the Massachusetts Port Authority (Massport) to construct and operate a cargo facility. The property, located in East Boston, was previously taxable before Massport acquired it in 1990. In 2017, the City of Boston began taxing the property, and the taxpayer sought abatements for the tax years 2017 through 2020, which were denied by the city's board of assessors.The taxpayer appealed to the Appellate Tax Board, arguing that section 53 of the 1993 supplemental appropriations bill exempted it from taxation because the property was used for "air transportation purposes." The board invited the parties to address whether section 53 had amended section 17 of the Massport enabling act, which governs the taxation of Massport lessees. The board concluded that section 53 was not enacted because the Senate did not finalize its reconsideration of the Governor's veto before the end of the 1993 legislative session. The board also determined that the property was leased for "business purposes" under section 17, making the taxpayer subject to taxation.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the Senate's initial vote to override the Governor's veto of section 53 was not final due to a timely motion to reconsider, which was not resolved before the legislative session ended. Therefore, section 53 did not amend section 17. The court also upheld the board's interpretation that "business purposes" under section 17 includes commercial, for-profit activities, and found that the taxpayer leased the property for such purposes. Consequently, the taxpayer was subject to taxation under section 17. View "480 McClellan LLC v. Board of Assessors of Boston" on Justia Law

John Doe, an individual with a serious mental illness, sued James V. McDonald, M.D., New York’s Commissioner of Health, and other defendants, seeking declaratory and injunctive relief under the Americans with Disabilities Act, the Rehabilitation Act, the Fair Housing Act, and Article 78 of the New York Civil Practice Law and Rules. Doe alleged that New York State regulations discriminated against him by preventing his readmission to Oceanview Manor Home for Adults, a Transitional Adult Home (TAH) where he previously resided. After filing the suit, the State allowed Doe to return to Oceanview, amended the regulations to permit readmission of former TAH residents with serious mental illness, and removed Oceanview’s classification as a TAH.The United States District Court for the Northern District of New York denied the State’s motion for summary judgment, which argued that Doe lacked standing. The district court granted the State leave to file an interlocutory appeal. On appeal, the State contended that the district court erred in finding standing because Doe lacked a concrete plan to leave and seek readmission to Oceanview.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the State’s jurisdictional challenge should be assessed as a question of mootness, not standing, because it addressed events occurring after Doe filed the suit. The court found that Doe’s suit was moot because the State had allowed Doe to return to Oceanview, amended the regulations, and removed Oceanview’s TAH classification. Consequently, there was no reasonable expectation that the alleged violation would recur.The Second Circuit dismissed the appeal, vacated the district court’s order, and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. View "Doe v. McDonald" on Justia Law

Vietnamese refugees and residents of San Diego County, Anh Thai and Don Doan, alleged that two law enforcement officers, Dulce Sanchez and William Villasenor, violated their constitutional rights by forcibly entering their homes and interrogating them about their disability benefits. Sanchez and Villasenor were Los Angeles District Attorney’s Office investigators assigned full-time to a joint federal-state task force, the Cooperative Disability Investigations (CDI) Unit, which investigates fraud in Social Security disability benefits applications. The plaintiffs claimed that the officers displayed guns and state badges, did not seek consent for the search, and failed to have an interpreter present during the investigations.The United States District Court for the Southern District of California granted summary judgment in favor of Sanchez and Villasenor, concluding that the officers were acting under color of federal law, not state law, and therefore could not be held liable under 42 U.S.C. § 1983. The district court found that the CDI Unit was implemented under federal authority, and the officers’ day-to-day work was supervised by a federal officer, Special Agent Glenn Roberts.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that because the CDI Unit was created under federal authority and supervised by a federal officer, Sanchez and Villasenor were acting under color of federal law. The court noted that the officers’ paychecks were reimbursed by the Social Security Administration, and their investigations took place outside of Los Angeles County, further indicating their federal role. Consequently, the officers were not subject to suit under § 1983, which applies to actions under color of state law. The court affirmed the district court’s summary judgment in favor of the defendants. View "Thai v. County of Los Angeles" on Justia Law

Isak Aden's ex-girlfriend called 911 on July 2, 2019, reporting that Aden had pointed a gun at her and ordered her to drive. She escaped, and Aden fled into a wooded area. Officers found Aden holding a gun to his head and began negotiating with him. Despite multiple attempts to get him to surrender, Aden refused and moved closer to his gun. Officers devised a tactical plan involving flashbangs and foam bullets to disorient Aden and arrest him. When the plan was executed, Aden reached for his gun, and officers fired lethal rounds, resulting in his death.The United States District Court for the District of Minnesota partially denied the defendants' motion for summary judgment, finding that the officers were not entitled to qualified or official immunity and that the City of Eagan could be liable under Monell. The court dismissed some claims but allowed others to proceed, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the officers' actions were reasonable under the circumstances and that they did not violate Aden's constitutional rights. The court held that the officers were entitled to qualified immunity because their use of force was not excessive. The court also found that the City of Eagan was not subject to Monell liability because there was no constitutional violation by the officers. Additionally, the court held that the officers were entitled to official immunity under Minnesota law, and thus, the City of Eagan was also entitled to vicarious official immunity.The Eighth Circuit reversed the district court's partial denial of summary judgment and remanded the case for entry of summary judgment based on qualified and official immunity. View "Aden v. City of Eagan" on Justia Law

Donald Hunter, a former coal miner, applied for benefits under the Black Lung Benefits Act (BLBA) in 2019, claiming that he was totally disabled due to chronic obstructive pulmonary disease (COPD) caused by his coal mine employment. Southern Ohio Coal Company, his former employer, contested his claim, arguing that Hunter's COPD was caused by his significant history of smoking cigarettes rather than coal mine dust exposure.An Administrative Law Judge (ALJ) reviewed the case and awarded benefits to Hunter, finding that his COPD constituted legal pneumoconiosis and that it was a substantially contributing cause of his total disability. Southern Ohio Coal appealed to the Benefits Review Board (BRB), arguing that the ALJ erred in discrediting its evidence and in crediting Hunter's evidence. The BRB affirmed the ALJ's decision, holding that the ALJ had properly considered and weighed the evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Southern Ohio Coal argued that the ALJ erred by relying on a pulmonary function test (PFT) that did not comply with regulatory quality standards and by relieving Hunter of his burden to establish entitlement to benefits. The court found that the ALJ acted within his discretion in determining that the PFT was compliant and supported Hunter's entitlement to benefits. The court also held that the ALJ did not improperly rely on regulatory guidance or flip the burden of proof to Southern Ohio Coal. The ALJ's decision was supported by substantial evidence, including expert opinions and Hunter's testimony.The Sixth Circuit denied the petition for review, affirming the ALJ's decision to award benefits to Hunter. The court held that the ALJ correctly applied the law and that his decision was supported by substantial evidence. View "Southern Ohio Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

A young child, Rustin Atkerson, tragically died from severe head trauma while under the care of his mother, Elaine Hurd, and her boyfriend, who had a history of domestic violence. Rustin's father, Ian Atkerson, and Rustin's estate sued the Department of Children, Youth, and Families (DCYF), alleging that their negligent investigation into reports of Rustin's injuries, including a broken arm, led to his death.The trial court denied DCYF's motion for summary judgment, ruling that Atkerson only needed to prove ordinary negligence, not gross negligence, to prevail. The court also largely excluded the testimony of retired Judge Kitty Ann Van Doorninck, who was to testify that a reasonable judge would not have removed Rustin from his mother's care based on the information available at the time. The trial court found her testimony would be unduly prejudicial.The Court of Appeals reversed the trial court's rulings, holding that the applicable standard of care was gross negligence and that the trial court erred in excluding Judge Van Doorninck's testimony. The case was then brought before the Supreme Court of the State of Washington.The Supreme Court of the State of Washington affirmed the Court of Appeals' decision, holding that RCW 4.24.595(1) applies to the early stages of child abuse and neglect investigations, requiring proof of gross negligence. The court also held that the trial court abused its discretion in excluding Judge Van Doorninck's testimony, as her testimony was relevant to the core issue of whether any negligence by the State caused a harmful placement decision. The case was remanded to the trial court for further proceedings consistent with this opinion. View "Atkerson v. State of Washington, Department of Children, Youth & Families" on Justia Law

The case involves a False Claims Act (FCA) suit alleging that U.S. Cellular and other entities committed fraud in Federal Communications Commission (FCC) wireless spectrum auctions. The alleged fraud involved using sham small businesses to obtain and retain bidding discounts worth millions of dollars. The district court dismissed the qui tam action because a previous lawsuit had raised substantially the same allegations, triggering the FCA’s public disclosure bar, and the relators bringing the action were not original sources of the information.Previously, the law firm Lampert, O’Connor & Johnston, P.C., filed a qui tam action in 2008 alleging that the same defendants conspired to register sham designated entities to obtain and hold discounted spectrum licenses for U.S. Cellular’s use. The government investigated but declined to intervene, and the law firm voluntarily dismissed the action. In 2015, Sara Leibman and Mark O’Connor filed a new complaint in federal court in Oklahoma, asserting FCA claims against the same defendants. The case was transferred to the District of Columbia, where the district court found the complaint asserted substantially the same allegations as the 2008 action, triggering the public disclosure bar, and dismissed the action.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court’s decision. The court held that the relators’ allegations were substantially the same as those in the 2008 qui tam action, thus triggering the FCA’s public disclosure bar. The court also found that the relators did not qualify as original sources of the information because their contributions did not materially add to the publicly disclosed allegations. Consequently, the court affirmed the dismissal of the qui tam action. View "USA v. USCC Wireless Investment, Inc." on Justia Law

Pirelli Tyre Co., Ltd. (Pirelli China), a foreign producer and exporter of certain tires, sought to establish independence from the Chinese government to obtain a separate antidumping duty rate. The United States Department of Commerce conducted an administrative review of merchandise covered by a 2015 antidumping-duty order for tires from China, covering entries between August 1, 2017, and July 31, 2018. Commerce applied a rebuttable presumption that all exporters within China are subject to government control, assigning a PRC-wide antidumping-duty rate unless the exporter demonstrates sufficient independence.The United States Court of International Trade (Trade Court) upheld Commerce’s determination that Pirelli China had not demonstrated its independence from government control. Commerce found that Pirelli China did not show autonomy from the Chinese government in selecting its management, a key criterion for obtaining a separate rate. Pirelli China’s arguments based on Italian law were rejected because the relevant provisions were not included in the record.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the Trade Court’s decision. The court held that Commerce’s interpretation of the rebuttable presumption and its requirement for Pirelli China to demonstrate autonomy from government control were reasonable. The court also found that Commerce’s determination was supported by substantial evidence, including the indirect ownership and control by state-owned enterprises and the shared management between Pirelli entities and Chinese government-controlled entities. The court concluded that Commerce acted within its discretion in rejecting Pirelli China’s unsupported interpretations of Italian law and upheld the assignment of the PRC-wide antidumping-duty rate to Pirelli China. View "PIRELLI TYRE CO., LTD. v. US " on Justia Law