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

A non-profit organization, Citizens for Constitutional Integrity, sued the Census Bureau, the Department of Commerce, and related officials, alleging that the Bureau failed to proportionately reduce the basis of representation for states in the 2020 Census as required by the Fourteenth Amendment's Reduction Clause. Citizens claimed this failure diluted the voting power of its members in New York, Pennsylvania, and Virginia. The organization sought relief under the Administrative Procedure Act (APA) and a writ of mandamus.The United States District Court for the District of Columbia dismissed the case for lack of standing. The court found that Citizens could not demonstrate that its alleged vote dilution injury was traceable to the Bureau's actions. Specifically, the court noted that Citizens failed to show how the Bureau's failure to apply the Reduction Clause directly caused the loss of congressional representation for the states in question. The court also found the data scientist's declaration provided by Citizens unpersuasive, as it did not adequately account for the number of disenfranchised voters in the relevant states.The United States Court of Appeals for the District of Columbia Circuit affirmed the District Court's dismissal. The appellate court held that Citizens did not establish traceability under Article III standards. The court found that Citizens failed to present a feasible alternative methodology for apportionment that would have resulted in a different allocation of seats for New York, Pennsylvania, and Virginia. The court also rejected Citizens's argument that it was entitled to a relaxed standing requirement for procedural-rights cases, concluding that the challenge was substantive rather than procedural. Consequently, the court affirmed the District Court's ruling that Citizens lacked standing to pursue its claims. View "Citizens for Constitutional Integrity v. Census Bureau" on Justia Law

Michael Riley, a former Capitol Police officer, was convicted of obstructing a federal grand jury investigation into the January 6, 2021, attack on the U.S. Capitol. The day after the attack, Riley advised a rioter, Jacob Hiles, to delete a Facebook post admitting he had been inside the Capitol. When Riley learned that his communications with Hiles might be investigated, he deleted their direct messages and call logs. A jury convicted Riley of one count of obstruction of an official proceeding under 18 U.S.C. § 1512(c)(1) for these deletions but could not reach a verdict on another count related to his advice to Hiles.The District Court for the District of Columbia sentenced Riley to probation and a fine. Riley appealed, arguing that the government failed to prove that a grand jury proceeding was foreseeable or that he intended to obstruct such a proceeding. He also claimed various trial errors.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the indictment sufficiently alleged that Riley intended to obstruct a foreseeable grand jury proceeding. The evidence showed that Riley, an experienced officer, knew that felony charges were likely for those involved in the Capitol breach and that a grand jury would be convened. The court also held that Riley's deletion of messages had a clear nexus to the foreseeable grand jury investigation.Riley's claims of constructive amendment and prejudicial variance were rejected, as the evidence at trial matched the indictment's allegations. The court also found no abuse of discretion in the district court's partial denial of Riley's discovery requests and rejected his claim of judicial bias.The D.C. Circuit affirmed Riley's conviction, holding that the government had sufficiently proven that Riley intended to obstruct a foreseeable grand jury proceeding by deleting his communications with Hiles. View "USA v. Riley" on Justia Law

The plaintiffs, the estate and family members of Yael Botvin, sued their former lawyers for legal malpractice. Yael Botvin was killed in a 1997 Hamas suicide bombing. In 2005, the plaintiffs hired the law firm Heideman Nudelman & Kalik, P.C. to sue Iran for sponsoring the attack. They won default judgments but only after nearly eight years, which prevented them from participating in a 2012 settlement agreement that disbursed Iranian assets seized in the U.S. The plaintiffs allege that the lawyers' negligence caused the delay, resulting in a lower recovery.The United States District Court for the District of Columbia dismissed the complaint, holding that while the plaintiffs adequately pleaded that the alleged negligence was a but-for cause of their lower recovery, they did not adequately plead proximate cause due to a lack of foreseeability. The court found that the specific sequence of events leading to the plaintiffs' reduced recovery was not foreseeable.The United States Court of Appeals for the District of Columbia Circuit reversed the district court's decision. The appellate court held that a jury could reasonably find that the plaintiffs' reduced recovery was a foreseeable result of the lawyers' alleged negligence. The court emphasized that the foreseeability requirement does not demand that the precise injury or method of harm be foreseen, only that the type of harm be foreseeable. The court concluded that the question of foreseeability in this case raised a jury question based on the facts alleged. The case was remanded for further proceedings consistent with this opinion. View "Estate of Botvin v. Heideman, Nudelman & Kalik, P.C." on Justia Law

Lake Region Healthcare Corporation operates a hospital in Minnesota and experienced a significant decrease in Medicare inpatient discharges in 2013, qualifying it for a volume-decrease adjustment (VDA). The hospital sought an adjustment of $1,947,967 using a method that estimates the portion of Medicare payments attributable to fixed costs. A Medicare contractor denied the adjustment, applying a method that treats all Medicare payments as compensation for fixed costs, resulting in no adjustment. The Provider Reimbursement Review Board (PRRB) reversed the contractor's decision, but the Centers for Medicare & Medicaid Services (CMS) reinstated it.The United States District Court for the District of Columbia ruled in favor of the government, deferring to CMS's method under Chevron deference. The court found that the statute did not specify how to calculate the VDA and that CMS's method was a reasonable interpretation, even if not the best one. The court concluded that CMS's approach was consistent with the statutory requirement to compensate only for fixed costs.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that CMS's method of attributing all Medicare payments to fixed costs did not comply with the statutory requirement to fully compensate hospitals for their fixed costs. The court noted that Medicare payments cover both fixed and variable costs and that CMS's method overstates the amount of reimbursed fixed costs, thus understating unreimbursed fixed costs. The court found that reasonable proxies exist to estimate the fixed-cost component of Medicare payments and that CMS's method was not a reasonable approximation of full compensation for fixed costs.The court reversed the district court's decision, granted summary judgment to Lake Region, and remanded the case to the agency for further proceedings consistent with the opinion. View "Lake Region Healthcare Corporation v. Becerra" on Justia Law

K.N., an eight-year-old boy with multiple disabilities, lives in a non-wheelchair-accessible apartment in the District of Columbia. His mother, Margda Pierre-Noel, requested that the District and his school, Bridges Public Charter School, provide assistance to move K.N. from their apartment door to the school bus. The District denied the request, citing its policy that staff only retrieve students from the outermost door of their dwelling and do not physically lift or carry students.The Office of the State Superintendent of Education (OSSE) hearing officer ruled that it was beyond his authority to order the requested assistance but required OSSE to offer transportation services to and from the outer door of K.N.'s apartment building. Pierre-Noel then filed a lawsuit in the United States District Court for the District of Columbia, which granted summary judgment in favor of the District, ruling that the service requested was not a transportation service under the Individuals with Disabilities Education Act (IDEA).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the IDEA requires the District to provide door-to-door transportation services for K.N., as such services are necessary for him to benefit from his special education. The court found that the term "transportation" under the IDEA includes moving a child from their apartment door to the vehicle that will take them to school. The court vacated the district court's grant of summary judgment and remanded the case for further proceedings consistent with its opinion. The appeal was dismissed as moot with respect to Bridges Public Charter School, as K.N. was no longer enrolled there. View "Pierre-Noel v. Bridges Public Charter School" on Justia Law

Terrell Armstead was convicted of sex trafficking through coercion. During jury deliberations, a juror was dismissed for failing to disclose her father's criminal history during voir dire. The district court then instructed the jury to return any partial verdicts due to the COVID-19 pandemic, which made future deliberations impossible. Armstead argued that the juror's dismissal and the instruction to return a partial verdict were improper.The United States District Court for the District of Columbia dismissed the juror for lack of candor during voir dire, noting multiple instances where she failed to disclose her father's convictions. The court found this misconduct sufficient to justify her removal, independent of her views on the evidence. The jury, after the dismissal, returned a guilty verdict on one count and no verdict on the remaining counts. Armstead was sentenced to 276 months in prison.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the district court did not abuse its discretion in dismissing the juror, as her lack of candor during voir dire constituted good cause under Federal Rule of Criminal Procedure 23(b)(3). The appellate court also found that the instruction to return a partial verdict was not coercive and did not violate the Sixth Amendment. The instruction was neutral and did not pressure the jury to reach a verdict. The appellate court affirmed the district court's judgment. View "USA v. Armstead" on Justia Law

Four aliens who were denied asylum and an organization assisting them filed FOIA requests for copies of the aliens’ Assessments to Refer and associated documents. USCIS released the factual portions of the Assessments but withheld portions containing analysis by the asylum officers, including opinions, deliberations, and recommendations regarding each applicant’s eligibility for asylum. The plaintiffs sued to obtain the full Assessments.The United States District Court for the District of Columbia granted summary judgment to the government. It held that the deliberative-process privilege covers the requested Assessments and that USCIS had adequately shown that releasing the withheld portions would foreseeably harm USCIS’s interest in receiving candid recommendations from its asylum officers. After the plaintiffs appealed, the case was remanded for further consideration in light of a new decision, Reporters Committee for Freedom of the Press v. FBI. On remand, USCIS submitted a supplemental declaration elaborating on the agency’s assessment of foreseeable harm, and the district court again granted summary judgment to DHS.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the deliberative-process privilege applies to the four requested Assessments and that DHS adequately showed that disclosure of their analysis portions would foreseeably harm interests the privilege protects. The court found that the supplemental declaration provided by USCIS’s Chief FOIA Officer sufficiently demonstrated foreseeable harm by explaining the sensitive nature of asylum adjudications and the specific concern about facilitating asylum fraud. The court affirmed the summary judgment for DHS. View "Emuwa v. DHS" on Justia Law

The case involves the U.S. Sugar Corporation and other industry petitioners challenging the Environmental Protection Agency's (EPA) 2022 rule that classified certain industrial boilers as "new" sources of hazardous air pollutants, even though they were built before the applicable emission standards were proposed in 2020. The EPA used a 2013-era dataset to establish these standards, excluding more recent data to maintain consistency with still-valid 2013 standards. Environmental petitioners argued that this exclusion violated the Clean Air Act.The U.S. Court of Appeals for the District of Columbia Circuit reviewed the case. The lower court had previously remanded the EPA's 2011 rule without vacatur, allowing the invalid standards to remain while the EPA revised them. The industry petitioners argued that the EPA's classification of boilers built after June 4, 2010, as "new" sources was incorrect, as these boilers were constructed before the 2020 proposal of the new standards. The environmental petitioners contended that the EPA's decision to use outdated data was arbitrary and capricious.The D.C. Circuit held that the EPA's classification of boilers built before August 24, 2020, as "new" sources was incorrect under the Clean Air Act. The court found that the proper date to determine whether a boiler is "new" should be when each specific emission standard is first proposed, not when any standard for the category was first proposed. Therefore, the court set aside the EPA's 2022 rule to the extent that it defined sources constructed before August 24, 2020, as "new."The court also held that the EPA's decision to rely on the 2013-era dataset was neither unlawful nor arbitrary and capricious. The court found that the EPA's choice was reasonable given the limited nature of the remand and the need for consistency across standards. Thus, the court denied the environmental petitioners' petition for review. View "United States Sugar Corporation v. EPA" on Justia Law

Holtec International applied to the Nuclear Regulatory Commission (NRC) for a license to construct and operate a spent nuclear fuel storage facility in New Mexico. The NRC denied multiple requests for intervention and a hearing from various petitioners, including Beyond Nuclear, Sierra Club, and Fasken Land and Minerals. These petitioners argued that the NRC acted unreasonably and contrary to law in denying their requests.The Atomic Safety and Licensing Board (Board) found the petitioners' contentions inadmissible and denied their petitions to intervene. The NRC affirmed the Board’s decisions. Beyond Nuclear, Environmental Petitioners (including Sierra Club), and Fasken each petitioned for review of the orders denying intervention. The case was held in abeyance until the NRC issued Holtec a license, after which the case was removed from abeyance for review by the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit reviewed the petitions and found that the NRC reasonably declined to admit the petitioners' factual contentions and complied with statutory and regulatory requirements. The court held that Beyond Nuclear did not raise a genuine dispute of law or fact regarding the NRC’s authority to consider Holtec’s application. The court also found that Environmental Petitioners failed to demonstrate any genuine disputes of material fact or law in their contentions related to statutory authority, alleged misrepresentations by Holtec, and compliance with the National Environmental Policy Act (NEPA). Additionally, the court determined that Fasken’s late-filed contentions were procedurally defective, untimely, and immaterial.The court denied all the petitions for review, affirming the NRC’s decisions to deny the requests for intervention. View "Beyond Nuclear, Inc. v. NRC" on Justia Law

Pacific Gas and Electric Company (PG&E) and the San Francisco Public Utilities Commission (SFPUC) have a longstanding dispute over PG&E's obligation to wheel energy to SFPUC's customers. SFPUC generates power and sells it to end users in San Francisco but relies on PG&E to distribute this energy. The disagreement centers on which consumers are entitled to wheeled service under a grandfathering clause in PG&E's 2015 Tariff, which incorporates a statutory provision allowing wheeling for consumers served by SFPUC as of October 24, 1992.Initially, the Federal Energy Regulatory Commission (FERC) rejected SFPUC's class-based approach, which argued that PG&E should wheel energy to the same types of customers served in 1992. FERC's 2019 order was vacated by the United States Court of Appeals for the District of Columbia Circuit, which remanded the case for FERC to provide a reasoned analysis of the statutory requirements. On remand, FERC adopted a class-based interpretation, allowing wheeling to all customers of the same class served in 1992, not just specific end users.The United States Court of Appeals for the District of Columbia Circuit reviewed FERC's orders and found them contrary to law. The court held that the plain meaning of "ultimate consumer" in the statutory provision refers to specific end users, not classes of consumers. The court emphasized that the statutory text does not support a class-based interpretation and that such an interpretation would undermine the primary restriction against FERC-ordered wheeling. Consequently, the court vacated FERC's orders and remanded the case for FERC to apply the plain meaning of the statute and determine which of SFPUC's consumers qualify for wheeled service under the 2015 Tariff. View "Pacific Gas and Electric Company v. FERC" on Justia Law