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

The case concerns two organizations that advocate for environmental health and public employee interests. They filed suit against the Environmental Protection Agency (EPA), alleging that the EPA failed to meet its statutory obligations under the Toxic Substances Control Act (TSCA) to address risks associated with perfluorooctanoic acid (PFOA), a harmful chemical formed during the fluorination of plastic containers. The plaintiffs argued that, by March 2023, the EPA had sufficient information about the dangers of PFOA to trigger a nondiscretionary duty to act under TSCA section 4(f), and, alternatively, a duty under section 7(a)(2) to pursue enforcement actions against a specific company involved in the fluorination process.The United States District Court for the District of Columbia reviewed the suit. It found that the EPA had fulfilled any nondiscretionary duty under section 4(f) by publishing a request for public comment, making the primary claim moot. Regarding section 7(a)(2), the court doubted that it imposed a nondiscretionary duty on the EPA but, even if it did, found that the duty had not been triggered under the circumstances. The District Court dismissed the complaint for lack of subject-matter jurisdiction, concluding that the claims did not fit within the TSCA’s citizen-suit provisions.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal, but on different grounds. The appellate court held that the organizations failed to plausibly allege associational standing. The court explained that neither organization was a traditional membership organization nor had they shown they were the functional equivalent of one. The court found insufficient evidence that the organizations’ employees, supporters, or board members constituted a constituency whose interests the organizations were entitled to represent in court. Accordingly, the appellate court dismissed the action for lack of jurisdiction. View "Public Employees for Environmental Responsibility v. Zeldin" on Justia Law

An individual disclosed information about significant misconduct at a large company to the news media. Following these disclosures, both Congress and staff from the Securities and Exchange Commission (SEC) contacted the individual for interviews and further information, which he provided. The SEC subsequently initiated an enforcement action against the company, relying on the information provided, resulting in substantial monetary sanctions. The individual then applied to the SEC for a whistleblower award under the Securities Exchange Act, which provides monetary awards to those who “voluntarily” provide “original information” leading to successful enforcement actions.The SEC denied the whistleblower award application, finding that the individual’s submission was not “voluntary” because it occurred only after the SEC and other authorities had contacted him. Additionally, the SEC found his submission was untimely and summarily denied his request for exemptions from these requirements. The individual challenged these determinations, arguing that the SEC’s interpretation of “voluntarily” conflicted with the statute's purpose and plain meaning, that his submission was timely, and that the denial of his request for exemptions was insufficiently explained and inconsistent with SEC precedent. He also raised First Amendment concerns, suggesting the SEC’s approach penalized whistleblowers for speaking to the press.The United States Court of Appeals for the District of Columbia Circuit reviewed the SEC’s order. The court held that the SEC’s interpretation of “voluntarily” was reasonable and consistent with statutory text and purpose, and rejected the First Amendment argument, finding it was based on a mistaken premise. However, the court found that the SEC abused its discretion by inadequately explaining its denial of the request for an exemption from the voluntariness requirement. The court thus denied the petition in part, granted it in part, vacated the denial of the exemption request, and remanded to the SEC for further consideration. View "Doe v. SEC" on Justia Law

A shipping dispute arose when a common carrier charged a trucking company detention fees for the late return of shipping equipment. The delay was caused by a COVID-19-related closure at the consignee’s plant, and when the trucking company attempted to return the equipment, the port was closed for three days due to scheduled closures and a holiday. The trucking company disputed a portion of the detention charges, arguing that it was impossible to return the equipment while the port’s gates were closed.The Federal Maritime Commission initially found the disputed charges unreasonable, concluding they could not have incentivized a faster return because the port was not accepting containers during the relevant days. The carrier sought review in the United States Court of Appeals for the District of Columbia Circuit, which vacated and remanded, instructing the Commission to address specific arguments and analyze the charges under the proper legal framework, especially the “incentive principle” as articulated in the Commission’s Interpretive Rule. On remand, the Commission reaffirmed that the charges were unreasonable. It emphasized that the purpose of detention fees is to promote freight fluidity and found that, under the uncontested facts—namely, the plant closure, the port’s closure, and the absence of costs to the carrier—the charges did not serve that purpose. The Commission also addressed and rejected each of the carrier’s justifications and extenuating circumstances.The United States Court of Appeals for the District of Columbia Circuit reviewed the Commission’s order on remand. The court held that the Commission’s determination was reasonable, supported by substantial evidence, and consistent with its Interpretive Rule. The court emphasized that the relevant standard is whether the charges promoted freight fluidity and found that the fees did not do so under the specific facts. The court denied the petition for review. View "Evergreen Shipping Agency (America) Corp. v. FMC" on Justia Law

An employee of a Texas electric utility company testified before a legislative committee about technical problems with the company's new smart meters, attributing fire hazards to the meters and referencing specific service calls. He was also the chief spokesperson for the union representing workers at the company, and he testified the day after unsuccessful collective bargaining negotiations. In his testimony, he identified himself as both an employee and a union representative, but did not mention the ongoing labor dispute or the negotiations. After learning of his remarks, the company terminated his employment, citing a violation of its policy against providing misleading information to public officials.An administrative law judge found that the employee’s testimony was protected under federal labor law, specifically section 7 of the National Labor Relations Act, which protects concerted activities for mutual aid or collective bargaining. The National Labor Relations Board agreed, concluding the company had committed unfair labor practices and ordering reinstatement and back pay. On review, the United States Court of Appeals for the District of Columbia Circuit previously found the testimony was not “maliciously untrue” but remanded for the Board to determine whether the employee’s speech sufficiently indicated it was connected to an ongoing labor dispute. On remand, the Board again found the discharge unlawful, reasoning that the context and the employee’s identification as a union representative sufficiently communicated the labor dispute connection.The United States Court of Appeals for the District of Columbia Circuit held that the employee’s statements were not protected because they did not disclose a connection to an ongoing labor dispute, as required by Supreme Court precedent. The court found the Board’s analysis legally erroneous and unsupported by substantial evidence. It therefore granted the company's petition for review, denied enforcement of the Board’s order, and vacated the finding of an unfair labor practice. View "Oncor Electric Delivery Company LLC v. NLRB" on Justia Law

An administrative law judge (ALJ) at the International Trade Commission (ITC) issued a protective order during a dispute between Qualcomm and Apple, requiring recipients of confidential business information, including expert witness Gregory Sidak, to return or destroy that information after the case ended. However, the ALJ who issued the order had been appointed solely by the ITC chairman, not by the full commission as required by the Constitution’s Appointments Clause. The ITC later ratified the ALJ’s appointments but did not ratify past actions taken by those ALJs. Years after the underlying case ended, the ITC began investigating Sidak for allegedly violating the protective order’s requirements. Sidak participated in the investigation by exchanging letters and affidavits, but eventually sued, arguing that the protective order was void because it was issued by an unconstitutionally appointed ALJ and never ratified, and sought to enjoin the ITC from enforcing it against him.The United States District Court for the District of Columbia found in Sidak’s favor, holding that the protective order could not lawfully be used as the basis for the investigation or for imposing sanctions on him. It permanently enjoined the ITC from taking further action against Sidak based on the challenged order. The ITC appealed the district court’s decision.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s judgment. The court held that Sidak had standing, that the district court had subject-matter jurisdiction, and that Sidak had a right of action under the Constitution. The court further held that Sidak’s challenge was both timely and ripe, rejecting the ITC’s arguments that the claim was either too early or too late. The court also concluded that the district court did not abuse its discretion in granting permanent injunctive relief. View "J. Sidak v. United States International Trade Commission" on Justia Law

Thirteen individuals and three nonprofit organizations challenged executive actions taken after the issuance of a presidential proclamation in January 2025, which responded to increased crossings at the southern border by suspending the entry of certain noncitizens and instituting new summary removal procedures. These new procedures, set out in subsequent agency guidance, barred individuals who crossed between ports of entry—or at ports without proper documentation—from seeking asylum or other statutory protections. The policies also established new, non-statutory removal processes that bypassed existing procedures and protections mandated by federal law.The United States District Court for the District of Columbia reviewed these policies in a putative class action. The court certified a class of all individuals subject to the proclamation, declared the agency guidance unlawful, vacated it, and enjoined agency officials from implementing similar actions under the proclamation. The district court found that the challenged policies supplanted the removal procedures and substantive protections Congress had established in the Immigration and Nationality Act (INA) and related regulations, including the right to apply for asylum, withholding of removal, and protection under the Convention Against Torture.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s summary judgment for the plaintiffs and affirmed the modified class certification. The D.C. Circuit held that Congress, in granting the President authority to suspend entry under the INA, did not authorize the executive to circumvent or override the statute’s exclusive and mandatory removal procedures or to categorically deny the right to apply for asylum and other protections. The court further held that neither the proclamation nor its guidance could lawfully suspend or replace statutory and regulatory processes for removal or for considering claims to asylum, withholding of removal, or Convention Against Torture protection. The court also upheld the district court’s class-wide relief and its scope under federal law. View "Refugee and Immigrant Center for Education and Legal Services v. Mullin" on Justia Law

In 2021, the United States seized over 700,000 barrels of crude oil from two tankers in the Mediterranean Sea. The government alleged that the oil belonged to the National Iranian Oil Company (NIOC), an entity it claimed materially supported the Islamic Revolutionary Guard Corps (IRGC), a designated Foreign Terrorist Organization. The government further asserted that NIOC’s activities included supplying, transporting, and selling oil to benefit the IRGC, which used these resources to fund terrorist activities targeting the United States. A Turkish commodities trading company, Aspan Petrokimya Co., claimed ownership of the seized oil and sought to recover the proceeds from its sale.The United States District Court for the District of Columbia initially dismissed the government’s forfeiture complaints without prejudice, finding that the government had not adequately pled that NIOC’s sale of oil affected foreign commerce. The government then filed an Amended Complaint consolidating the cases and providing additional factual detail. The district court denied Aspan’s renewed motion to dismiss, concluding that the amended allegations sufficiently addressed the jurisdictional element and all other statutory requirements. To expedite appellate review, Aspan admitted the complaint’s factual allegations, consented to judgment on the pleadings, and appealed.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s denial of the motion to dismiss de novo. The appellate court held that the government needed only to allege NIOC’s ownership of the property at the time of the offense, not at the time of seizure. The court also found that the Amended Complaint plausibly alleged that NIOC’s material support of the IRGC substantially affected foreign commerce, and that NIOC’s actions were calculated to influence the U.S. government. The court affirmed the district court’s judgment. View "USA v. All Petroleum-Product Cargo Onboard the M/T Arina" on Justia Law

A charity gala honoring Joan Hisaoka was held annually at the Omni Shoreham Hotel in Washington, D.C., with Inova Health Care Services contracting with the hotel for the event and the Smith Center for Healing and the Arts providing financial support. In December 2018, Inova and Omni executed an agreement specifying that the 2019 Gala would be held in the Ambassador and Regency Ballrooms. The contract did not include Omni’s standard clause permitting reassignment of event spaces. A few months before the event, Omni informed Inova it would relocate the Gala to less desirable spaces to accommodate a higher-paying client. Inova objected, found the alternative spaces unsuitable, and relocated the Gala to another venue. Smith Center, though not a party to the contract, paid the deposit as in prior years.The United States District Court for the District of Columbia initially denied both parties’ motions for summary judgment. Upon reconsideration, it granted summary judgment on liability to Inova and Smith Center, finding Omni had breached the contract’s express terms and the implied covenant of good faith and fair dealing. The court limited Omni’s mitigation defense and the case proceeded to a jury trial on damages, resulting in awards to both Inova and Smith Center.The United States Court of Appeals for the District of Columbia Circuit affirmed summary judgment and the jury’s damages award in favor of Inova, holding there was no genuine dispute that Omni materially breached the contract and acted in bad faith. The court also held the district court properly precluded Omni’s mitigation defense regarding the alternative spaces. However, the appellate court vacated the damages award to Smith Center, finding a genuine factual dispute regarding its status as an intended third-party beneficiary, and remanded for further proceedings on that issue. View "Inova Health Care Services v. Omni Shoreham Corporation" on Justia Law

Eighteen transgender women incarcerated in federal women’s prisons challenged a federal executive order that directed the Attorney General to ensure that “males”—defined by biological sex assigned at conception—are not detained in women’s facilities. These plaintiffs were a small group of transgender women whom the Bureau of Prisons had, after individualized assessments, placed in women’s facilities. Each had been diagnosed with gender dysphoria, received long-term hormone therapy, and some had undergone gender-affirming surgeries. The plaintiffs alleged that transferring them to men’s prisons would expose them to grave risks of violence, abuse, and psychological harm.The United States District Court for the District of Columbia granted the plaintiffs preliminary injunctive relief, blocking their transfers and requiring the government to maintain their housing in women’s facilities. The district court found that transgender women are at a significantly higher risk of harm in men’s facilities and that the government was aware of these risks. The court also rejected government arguments that judicial review was barred or that the plaintiffs had failed to exhaust administrative remedies, holding instead that no effective administrative remedy was available.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The appellate court held that judicial review of constitutional claims was not barred by statute and that the government had not shown exhaustion of available administrative remedies. However, the court vacated the preliminary injunctions, finding that the district court’s broad, categorical reasoning was not defended by the plaintiffs on appeal, who instead advanced more individualized grounds. The record did not contain the necessary factual findings as to each plaintiff’s specific vulnerabilities. The case was remanded for further proceedings, and the expired injunctions were dismissed as moot. View "Doe v. Blanche" on Justia Law

KC Transport, an independent trucking company, provides hauling services for mining and other companies. It operates a maintenance facility for its haul trucks about a mile from one of its primary client’s active mines. During an inspection, a Mine Safety and Health Administration (MSHA) inspector observed two KC Transport trucks at the facility undergoing maintenance in conditions that violated federal safety standards—specifically, the trucks were raised and unblocked, with one worker standing underneath. The inspector issued citations for these violations.In an administrative proceeding, KC Transport contested the citations, arguing that MSHA lacked jurisdiction over its facility and trucks since they were not located at an extraction site or on an appurtenant road. An administrative law judge (ALJ) found that MSHA had jurisdiction, reasoning that the facility and trucks were “used in” mining-related activities and thus constituted a “mine” under the Federal Mine Safety and Health Amendments Act. KC Transport appealed, and the Federal Mine Safety and Health Review Commission reversed the ALJ, holding that only facilities or equipment located at extraction sites or appurtenant roads qualify as “mines” under the Act and vacated the citations.The Secretary of Labor, acting through MSHA, petitioned the United States Court of Appeals for the District of Columbia Circuit for review. After an intervening Supreme Court decision overruled Chevron deference, the D.C. Circuit independently interpreted the relevant statutory provisions. The court held that a “facility” constitutes a “mine” under the Mine Act when it is necessarily connected with the use and operation of extracting, milling, or processing minerals, even if not located directly at an extraction site or appurtenant road. Concluding that KC Transport’s facility met this definition, the court vacated the Commission’s decision and affirmed the Secretary’s citations. View "Secretary of Labor v. KC Transport, Inc." on Justia Law