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

A group of organizations and a resident challenged a plan by the Federal Aviation Administration (FAA) and the National Park Service (NPS) regulating tourist flights over four national parks near San Francisco. The agencies determined that no environmental analysis was needed under the National Environmental Policy Act (NEPA) because the plan would cause minimal additional environmental impact compared to existing conditions.The U.S. Court of Appeals for the District of Columbia Circuit reviewed the case. The court noted that the agencies had previously announced their intent to prepare an environmental assessment but later terminated that process. The agencies then decided to use the existing number of flights as the baseline for their environmental analysis, concluding that the plan would have no significant environmental impact.The court held that the agencies acted arbitrarily by using the existing flights under interim operating authority as the baseline for their NEPA analysis. This approach effectively enshrined the status quo without evaluating the environmental impacts of the existing flights. The court found that the agencies' reliance on interim operating authority as the baseline was unreasonable and contrary to their duties under the National Parks Air Tour Management Act and NEPA.The court vacated the FAA's order and remanded the case for further proceedings, instructing the agencies to conduct a proper NEPA analysis. The court also noted that the agencies could move for a stay of the mandate if they wished to keep the current plan in place while conducting the new analysis. View "Marin Audubon Society v. FAA" on Justia Law

The appellants, Andrew Hanson and others, challenged the District of Columbia's law that limits firearm magazine capacity to 10 rounds. They argued that this restriction violates their Second Amendment rights, particularly in light of the Supreme Court's decision in N.Y. State Rifle & Pistol Ass’n v. Bruen, which emphasized historical traditions of firearm regulation over means-end scrutiny.The United States District Court for the District of Columbia denied the appellants' motion for a preliminary injunction. The court conducted a renewed analysis under the Bruen framework, which involves determining whether the Second Amendment covers the conduct in question and, if so, whether the regulation is consistent with historical traditions. The district court found that while extra-large capacity magazines (ELCMs) are "arms" under the Second Amendment, their possession is not protected because they are not typically used for lawful purposes. Additionally, the court held that the District's magazine cap is consistent with historical firearm regulations aimed at reducing violence.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that ELCMs are "arms" under the Second Amendment and are in common use for self-defense. However, it found that the District's magazine cap is consistent with historical regulations of weapons that posed unprecedented lethality, such as Bowie knives and machine guns. The court also noted that the regulation addresses the modern societal concern of mass shootings, which did not exist at the time of the Founding.The court concluded that the appellants failed to demonstrate a likelihood of success on the merits or irreparable harm. It emphasized the importance of maintaining the status quo and the potential public safety risks of enjoining the magazine cap. Therefore, the court affirmed the district court's denial of the preliminary injunction. View "Hanson v. District of Columbia" on Justia Law

Jason Lee, an American citizen of Chinese ancestry, was employed by the FBI and held a Top Secret security clearance. After failing three polygraph examinations, the FBI revoked his security clearance and subsequently terminated his employment, as his job required such clearance. Lee contended that the revocation was based on race, national origin, and protected speech, and he brought claims under the First Amendment, the Fifth Amendment, and Title VII.The United States District Court for the District of Columbia dismissed Lee's claims. It held that his Title VII claims were not timely exhausted, that Title VII preempted his Fifth Amendment claims against the Department of Justice (DOJ), and that Lee lacked a cause of action to press constitutional claims for damages against individual DOJ officials. The court also denied Lee's motion for leave to amend his complaint to include additional claims.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Department of Navy v. Egan, 484 U.S. 518 (1988), barred judicial review of Lee's statutory and constitutional claims. The court reasoned that the decision to grant or revoke a security clearance is a sensitive and inherently discretionary judgment committed by law to the appropriate agency of the Executive Branch. The court also found that Lee's constitutional claims were nonjusticiable under the political question doctrine, as they involved national security matters committed to the political branches and lacked judicially manageable standards for resolution. View "Lee v. Garland" on Justia Law

The case involves a defendant who entered the U.S. Capitol grounds on January 6, 2021, during the certification of the Electoral College votes. The grounds were restricted to protect Vice President Pence, who was present. The defendant, along with others, breached the security perimeter and remained in the restricted area for about two hours. He was charged with knowingly entering and remaining in a restricted area without lawful authority, in violation of 18 U.S.C. § 1752(a)(1).The United States District Court for the District of Columbia conducted a bench trial and found the defendant guilty of violating 18 U.S.C. § 1752(a)(1). The court held that the government did not need to prove that the defendant knew the specific reason for the restriction, only that he knew the area was restricted. The court sentenced the defendant to fourteen days of incarceration and one year of supervised release.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the district court's judgment, holding that the statute requires only that the defendant knowingly entered or remained in a restricted area, not that he knew the specific reason for the restriction. The court emphasized that requiring proof of knowledge of the specific reason would undermine the statute's purpose of protecting Secret Service protectees. The court concluded that the evidence was sufficient to prove that the defendant knew the area was restricted when he entered and remained there. View "USA v. Griffin" on Justia Law

The appellant, a federal prisoner serving a twenty-two-year sentence, has a history of filing numerous lawsuits regarding his prison conditions. In this case, he sought to proceed in forma pauperis (IFP) under the Prison Litigation Reform Act (PLRA) despite having three prior cases dismissed as frivolous, malicious, or for failure to state a claim. He claimed imminent danger of serious physical injury due to worsening glaucoma and alleged that prison officials denied him necessary medical treatment and incited other inmates to assault him.The United States District Court for the District of Columbia denied his motion to proceed IFP, finding that he did not demonstrate imminent danger of serious physical injury. The court dismissed his case without prejudice. The appellant then appealed this decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court disagreed with the District Court's assessment regarding the appellant's glaucoma, finding that the appellant's allegations of being denied necessary medical treatment for his worsening glaucoma did place him under imminent danger of serious physical injury. Consequently, the court granted the appellant's motion to proceed IFP and reversed the District Court's denial of his motion, allowing his complaint to be docketed.However, the court also found that some of the appellant's claims were frivolous, particularly those against high-ranking officials such as the United States Attorney General and members of the United States Senate Judiciary Committee. These claims were dismissed under the PLRA's mandate to dismiss frivolous claims. The court's decision allowed the appellant to proceed with his claims related to his medical treatment and alleged assaults but dismissed the frivolous claims against the aforementioned officials. View "Owlfeather-Gorbey v. Avery" on Justia Law

In 2018, Campaign Legal Center (CLC) filed an administrative complaint with the Federal Election Commission (FEC) alleging that 45Committee, Inc. violated the Federal Election Campaign Act by not registering as a political committee. After nearly two years of inaction by the FEC, CLC sued the FEC, seeking a declaration that the FEC's failure to act was "contrary to law." The court agreed and ordered the FEC to act within thirty days. When the FEC did not appear to act within that period, the court allowed CLC to bring a citizen suit against 45Committee.The United States District Court for the District of Columbia initially found that the FEC had failed to act on CLC's complaint and issued a default judgment against the FEC. The court ordered the FEC to act within thirty days, but the FEC did not notify the court or CLC of any action taken. Consequently, the court allowed CLC to bring a citizen suit against 45Committee. However, it later emerged that the FEC had held a reason-to-believe vote within the thirty-day period, which failed to garner the necessary votes to proceed with an investigation or dismiss the complaint.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and concluded that the district court was correct in dismissing CLC's citizen suit. The appellate court held that the FEC's holding of a reason-to-believe vote within the thirty-day period constituted conformance with the contrary-to-law determination. Therefore, the preconditions for bringing a citizen suit were not met, as the FEC had taken the required action by holding the vote, even though the vote did not result in a decision to investigate or dismiss the complaint. The court affirmed the district court's dismissal of the citizen suit. View "Campaign Legal Center v. 45Committee, Inc." on Justia Law

NextEra Energy Resources, LLC and NextEra Energy Seabrook, LLC (collectively, "Seabrook") own a nuclear power plant in Seabrook, New Hampshire. Avangrid, Inc. and NECEC Transmission LLC (collectively, "Avangrid") sought to connect their New England Clean Energy Connect (NECEC) project to the regional transmission grid. The connection required Seabrook to upgrade its circuit breaker to handle the increased power flow. Seabrook and Avangrid agreed on the necessity of the upgrade and that Avangrid would cover the direct costs, but they disagreed on whether Seabrook should be compensated for indirect costs and whether Seabrook was obligated to upgrade the breaker without full compensation.The Federal Energy Regulatory Commission (FERC) ruled that Seabrook must upgrade the circuit breaker under the Large Generator Interconnection Agreement (LGIA) and that Avangrid was not required to reimburse Seabrook for indirect costs such as legal expenses and lost profits. Seabrook petitioned for review, arguing that FERC lacked statutory authority to require the upgrade and that the LGIA did not obligate them to upgrade the breaker without full compensation.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that FERC had statutory authority to require the upgrade because it directly affected the transmission of electricity in interstate commerce. The court also found that FERC correctly interpreted the LGIA to require Seabrook to maintain an adequate circuit breaker in light of changing grid conditions, including the interconnection of new generators like Avangrid. Additionally, the court upheld FERC's decision to deny compensation for indirect costs, reasoning that the tariff did not clearly and specifically cover such costs and that FERC's precedent generally did not allow for recovery of opportunity costs during interconnection outages.The court denied Seabrook's petitions for review, affirming FERC's orders. View "NextEra Energy Resources, LLC v. FERC" on Justia Law

In 1989, thirty-four members of the Kappa Gamma fraternity at Gallaudet University were photographed performing the Bellamy salute, which resembles the Nazi salute. Thirty years later, the president of Gallaudet described Kappa Gamma as the "face of systemic racism" at the university, and The Washington Post republished this statement, describing the photograph as depicting "anti-Semitic" behavior and a "Nazi salute." Four alumni of Gallaudet’s Kappa Gamma chapter, including the estate of a deceased member, sued Gallaudet and the Post for defamation and related torts.The United States District Court for the District of Columbia dismissed the complaint, concluding that none of the disputed statements concerned the plaintiffs and that many of the statements were not actionable. The plaintiffs appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and disagreed in part with the district court. The appellate court concluded that the statements about the photograph did concern the individuals who appeared in it. However, the court agreed with the district court that these statements were protected opinions and thus not actionable. The court held that the statements describing the students in the photograph as the "face of systemic racism" and "anti-Semitic" were not provably false and were therefore protected opinions. Consequently, the appellate court affirmed the district court's dismissal of the complaint. View "Florio v. Gallaudet University" on Justia Law

KalshiEx LLC, a regulated commodities exchange, sought to offer "Congressional Control Contracts" allowing individuals to bet on the outcome of the November 2024 congressional elections. The Commodity Futures Trading Commission (CFTC) prohibited these contracts, arguing they constituted gaming or election gambling, which is illegal in many states. Kalshi challenged this decision under the Administrative Procedure Act, claiming the CFTC's determination was arbitrary and capricious.The U.S. District Court for the District of Columbia ruled in favor of Kalshi, finding that the CFTC erred in categorizing the contracts as gaming or gambling. The court vacated the CFTC's decision, reasoning that the term "gaming" did not apply to election contracts and that the contracts did not involve illegal activity under state law. The CFTC then sought a stay of the district court's judgment while it pursued an appeal.The United States Court of Appeals for the District of Columbia Circuit reviewed the CFTC's emergency motion for a stay pending appeal. The court denied the motion, concluding that the CFTC failed to demonstrate that it or the public would suffer irreparable harm without a stay. The court noted that the CFTC's concerns about potential harms, such as market manipulation and threats to election integrity, were speculative and not substantiated by concrete evidence. The court left open the possibility for the CFTC to renew its stay request if more concrete evidence of irreparable harm emerged during the appeal. The administrative stay was dissolved. View "KalshiEX LLC v. CFTC" on Justia Law

In 2017, the Brotherhood of Railroad Signalmen (the Union) initiated proceedings against the National Railroad Passenger Corporation (Amtrak) in federal district court. The Union contested Amtrak’s refusal to use Union-represented signalmen in a newly acquired building. The district court sent the case to mandatory arbitration under the Railway Labor Act (RLA). The National Railroad Adjustment Board (the Board) dismissed the claim, stating it lacked jurisdiction because the Union was seeking relief based on hypothetical facts.The district court vacated the Board’s award and remanded for further proceedings, holding that the Board did not consider or interpret the parties’ agreement. Amtrak appealed, arguing that the award should be upheld under the highly deferential judicial standard of review because it was at least arguably based on rail industry common law and Rule 56 of the collective bargaining agreement.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s decision. The court found that the Board’s award should be vacated because it did not decide the dispute based on the parties’ contract. Instead, the Board relied on legal principles governing federal courts’ subject-matter jurisdiction, which are outside the scope of the Board’s authority. The court emphasized that the Board must interpret the contract and cannot base its decisions on external legal principles unrelated to the contract. The case was remanded to the district court with instructions to remand to the National Railroad Adjustment Board for proceedings consistent with the opinion. View "Brotherhood of Railroad Signalmen v. National Railroad Passenger Corporation" on Justia Law