Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

A computer scientist, Dr. Stephen Thaler, created an artificial intelligence system called the "Creativity Machine," which autonomously generated an artwork titled "A Recent Entrance to Paradise." Dr. Thaler submitted a copyright registration application to the United States Copyright Office, listing the Creativity Machine as the sole author and himself as the owner. The Copyright Office denied the application, citing its policy that only works authored by humans are eligible for copyright protection.Dr. Thaler sought review of the Copyright Office's decision in the United States District Court for the District of Columbia. The district court affirmed the Copyright Office's denial, holding that human authorship is a fundamental requirement under the Copyright Act of 1976. The court also rejected Dr. Thaler's argument that he should own the copyright under the work-made-for-hire doctrine, as the work was never eligible for copyright protection in the first place. Additionally, the court found that Dr. Thaler had waived his argument that he should be considered the author because he created and used the Creativity Machine.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 Copyright Act requires all eligible works to be authored by a human being. Since Dr. Thaler listed the Creativity Machine, a non-human entity, as the sole author, the application was correctly denied. The court did not address the argument that the Constitution requires human authorship, nor did it consider Dr. Thaler's claim that he is the author by virtue of creating and using the Creativity Machine, as this argument was waived before the agency. View "Thaler v. Perlmutter" on Justia Law

Hood River Distillers, Inc. operates a liquor distillery in Oregon, employing approximately twenty-five unionized employees represented by Teamsters Local Union No. 670. In January 2019, the Union and Hood River began negotiating a new collective bargaining agreement. The negotiations focused on health insurance, wages, and other benefits. Despite several bargaining sessions, the parties did not reach an agreement, and Hood River unilaterally implemented its final offer in May 2020, leading to a strike by the Union.The National Labor Relations Board (NLRB) found that Hood River violated the National Labor Relations Act (NLRA) by unilaterally changing employment terms without reaching an impasse in negotiations. Hood River argued that the Union engaged in unjustified delay tactics, justifying its unilateral actions. The administrative law judge (ALJ) ruled against Hood River, and the NLRB affirmed the ALJ's decision, finding that the Union's actions did not constitute unjustified delay tactics and that no impasse had been reached.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that substantial evidence supported the NLRB's conclusion that Hood River acted unlawfully by unilaterally implementing its March 30 offer. The court found that the Union's insistence on in-person mediation during the early stages of the COVID-19 pandemic was not unreasonable and did not constitute unjustified delay tactics. The court also noted that Hood River failed to preserve its challenge to the remedy awarded by the NLRB.The court denied Hood River's petition for review and granted the NLRB's cross-application for enforcement, affirming the NLRB's decision that Hood River violated the NLRA by unilaterally changing employment terms without reaching an impasse and without justification based on the Union's conduct. View "Hood River Distillers, Inc. v. NLRB" on Justia Law

Jones Lang LaSalle Americas, Inc. (JLL) provides building management services. In 2023, the International Union of Operating Engineers, Stationary Engineers, Local 39, AFL-CIO (Union) sought certification as the bargaining representative for JLL's Maintenance II and III technicians at an Amazon facility in Napa, California. The Union and JLL agreed to a stipulated election, which was approved by the NLRB's Regional Director. The election was held on May 17, 2023, and all four eligible employees voted in favor of Union representation. JLL refused to bargain with the Union and filed an objection to the election, claiming misconduct by the Board Agent overseeing the election.The Regional Director dismissed JLL's objections, finding them meritless, and certified the election. JLL appealed to the NLRB, which denied the appeal. JLL continued to refuse to bargain, leading the Board's General Counsel to file a complaint. In March 2024, the NLRB issued a summary judgment against JLL, finding that the company violated sections 8(a)(5) and (1) of the National Labor Relations Act by refusing to recognize and bargain with the Union. The Board ordered JLL to bargain with the Union.JLL then filed a petition for review with the United States Court of Appeals for the District of Columbia Circuit, reiterating its claim that the election should be set aside. The Board cross-petitioned for enforcement of its order. The Court of Appeals reviewed the case and found that the Regional Director's decision to certify the election without a hearing was reasonable and supported by substantial evidence. The court held that JLL's objections did not raise substantial and material factual issues that would justify setting aside the election. Consequently, the court denied JLL's petition for review and granted the Board's cross-application for enforcement of its order requiring JLL to recognize and bargain with the Union. View "Jones Lang LaSalle Americas, Inc v. NLRB" on Justia Law

Edward M.R., a special-education student in Washington, D.C.'s public schools, filed an administrative due process complaint on June 19, 2020, alleging that his individualized education plans (IEPs) from 2015 through 2019 were insufficient to meet his needs under the Individuals with Disabilities Education Act (IDEA). He claimed deficiencies in speech/language therapy, occupational therapy, and other areas. The hearing officer dismissed his claims, finding that challenges to his 2015, 2016, and 2017 IEPs were untimely and that his 2018 and 2019 IEPs were appropriate.Edward then sued in the United States District Court for the District of Columbia, challenging the hearing officer's determinations regarding the 2017, 2018, and 2019 IEPs. The district court affirmed the hearing officer's decisions, leading Edward to appeal.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that Edward's challenge to his 2017 IEP was untimely, as it was filed more than two years after he knew or should have known about the alleged deficiencies. Regarding the 2018 and 2019 IEPs, the court found that Edward failed to prove by a preponderance of the evidence that the hearing officer was wrong in concluding that the IEPs were appropriate. The court noted that repeating goals in the IEPs was reasonable given Edward's severe memory issues and that the IEPs included new, appropriately ambitious goals.The court also rejected Edward's claims that his IEPs lacked research-based instruction, finding that he received such instruction even if it was not explicitly stated in the IEPs. Finally, the court did not consider Edward's claim regarding the implementation of Applied Behavior Analysis, as it was not exhausted through the administrative process. The court affirmed the district court's decision. View "M.R. v. District of Columbia" 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

In 2005, the District of Columbia Fire and Emergency Medical Services Department implemented a policy prohibiting firefighters from wearing facial hair that interferes with the sealing surface of a face mask, effectively banning beards. Firefighters who refused to shave were reassigned to administrative duties and faced termination after four days of noncompliance. The Department did not make exceptions for religious reasons. A group of bearded firefighters sued, claiming the policy violated the Religious Freedom Restoration Act (RFRA). The district court ruled in favor of the firefighters, finding the policy was not the least restrictive means of furthering the Department's interest in operational effectiveness, and issued an injunction preventing enforcement of the policy against them.The firefighters were allowed to work in field operations with their beards until March 2020, when the Department implemented a new facial hair policy due to COVID-19, again reassigning bearded firefighters to administrative roles. The firefighters objected, claiming the new policy violated the 2007 injunction. After unsuccessful settlement negotiations, the firefighters filed a motion for civil contempt, alleging the Department violated the injunction. The district court denied the motion, reasoning that the Department acted reasonably under unprecedented circumstances and that any damages were minimal.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the district court applied the wrong legal framework by assuming it had general discretion to deny contempt despite a potential violation of the injunction. The appellate court vacated the district court's decision and remanded the case, instructing the lower court to determine whether the Department violated the 2007 injunction and if any recognized defenses to contempt applied. The court emphasized that good faith and lack of willfulness are not defenses to civil contempt. View "Potter v. District of Columbia" on Justia Law

The Human Rights Defense Center (HRDC), a non-profit organization, filed a Freedom of Information Act (FOIA) request with the United States Park Police for information about legal actions against the agency. After the Park Police failed to respond within the statutory period, HRDC filed a FOIA lawsuit. The Park Police eventually produced documents but withheld the names of officers involved in three tort settlements, citing FOIA Exemption 6, which protects against unwarranted invasions of personal privacy. Additionally, the Park Police inadvertently disclosed names in some documents and sought to prevent HRDC from using or disseminating this information.The United States District Court for the District of Columbia ruled that the Park Police correctly withheld the officer names under Exemption 6 and issued a clawback order for the inadvertently disclosed names, invoking its inherent authority to manage judicial proceedings.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Park Police failed to meet its burden under Exemption 6 to show that releasing the officer names would constitute a substantial invasion of privacy. The court found the agency's justifications to be generic and conclusory, lacking specific details. Consequently, the court did not need to balance the privacy interest against the public interest in disclosure.The court also determined that the district court's clawback order was not a valid exercise of inherent judicial authority, as it aimed to fill a perceived gap in the FOIA statute rather than protect core judicial functions. The court reversed the district court's summary judgment in favor of the Park Police, vacated the clawback order, and remanded the case for the release of the non-exempt officer names. View "Human Rights Defense Center v. United States Park Police" on Justia Law

The case involves the Cigar Association of America and other plaintiffs challenging a regulation by the FDA that applied to premium cigars. The FDA had issued a rule under the Family Smoking Prevention and Tobacco Control Act, which brought all tobacco products, including premium cigars, under its regulatory authority. The plaintiffs argued that the regulation was arbitrary and capricious as applied to premium cigars, citing studies that suggested premium cigars posed fewer health risks due to less frequent use.The United States District Court for the District of Columbia, presided over by Judge Mehta, found in favor of the plaintiffs. The court determined that the FDA had failed to consider relevant evidence, specifically the Corey study and Monograph No. 9, which indicated that premium cigars were used less frequently and posed fewer health risks. The district court vacated the FDA's rule as it applied to premium cigars, finding the agency's action arbitrary and capricious.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court agreed with the district court's finding that the FDA's rule was arbitrary and capricious because the agency ignored relevant data and falsely claimed that no such evidence existed. The appellate court upheld the vacatur of the rule as applied to premium cigars but remanded the case to the district court to invite further briefing on the appropriate definition of "premium cigars." The court emphasized that the vacatur should not allow for revisiting past user fee payments. The decision affirmed the district court's ruling in full, except for the need to refine the definition of premium cigars. View "Cigar Association of America v. FDA" on Justia Law

America First Legal Foundation (AFL) submitted Freedom of Information Act (FOIA) requests to fourteen federal agencies for strategic plans related to promoting voter registration and participation, as mandated by Executive Order 14019 issued by President Biden. The agencies did not respond favorably, leading AFL to file a lawsuit to compel disclosure of the documents. The agencies argued that the plans were protected by FOIA Exemption 5, which incorporates the presidential communications privilege.The United States District Court for the District of Columbia granted summary judgment in favor of the agencies, holding that the strategic plans were protected by the presidential communications privilege and thus exempt from FOIA disclosure. AFL appealed this decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court agreed with the district court, finding that the strategic plans were indeed protected by the presidential communications privilege. The court noted that the plans were solicited by the President, submitted to his close advisors, and used to inform presidential decision-making and deliberations. The court found no evidence in the record to contradict the government’s declarations that the plans were used in this manner. Consequently, the appellate court affirmed the district court’s judgment, upholding the exemption of the strategic plans from FOIA disclosure under the presidential communications privilege. View "America First Legal Foundation v. USDA" on Justia Law

On January 6, 2021, Ralph Joseph Celentano, III participated in the events at the United States Capitol, where he was involved in altercations with law enforcement officers. He was convicted by a jury on six counts related to his conduct that day, including forcibly shoving Officer Kenrick Ellis off a ledge. Celentano challenged his convictions on several grounds, including errors in jury instructions and sentencing.The United States District Court for the District of Columbia convicted Celentano on six counts and acquitted him on one count. The district court sentenced him to 78 months of imprisonment on Count One, with concurrent sentences on the other counts, and 36 months of supervised release on Counts One and Two. Celentano appealed, arguing that the district court erred in its jury instructions and sentencing calculations.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the district court's jury instruction on the defense of another was erroneous because it required the jury to consider the use of force from the perspective of a reasonable law enforcement officer rather than from Celentano's perspective. This error was not harmless regarding Count One, leading the court to vacate Celentano's conviction on that count. However, the error was deemed harmless for Counts Two, Five, and Six due to overwhelming evidence of Celentano's other violent acts.The court also addressed Celentano's Double Jeopardy challenge, noting that it was no longer a live issue due to the vacatur of Count One. Additionally, the court rejected Celentano's challenge to the jury instructions on Counts Three, Four, and Five, citing precedent that the government only needed to prove Celentano knew he was in a restricted area.Finally, the court vacated Celentano's sentence due to several errors in the Sentencing Guidelines calculation and remanded the case for resentencing. The case was remanded to the district court for further proceedings, except for Count Seven. View "USA v. Celentano" on Justia Law