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

Defendant moved to suppress evidence found in his apartment after police officers executed a search warrant and seized drugs, firearms, cash, and a variety of drug paraphernalia. Defendant argued that the police officer who prepared the search warrant affidavit made false statements in the affidavit and did so with reckless disregard for the truth. The court reversed the district court's grant of the motion to suppress and concluded that, even with the contested statements excised, the remaining portions of the officer's affidavit demonstrated probable cause for the search warrant. View "United States v. Cardoza" on Justia Law

The District of Columbia appealed from the structural injunction entered by the district court in this class action challenging the policies and practices of the District's "Child Find" system under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court vacated the order certifying the class, and consequently, the orders finding liability and ordering relief to that class. The court remanded the case to the district court for reconsideration of whether a class, classes, or subclasses may be certified, and if so, thereafter to redetermine liability and appropriate relief. View "DL, et al v. DC, et al" on Justia Law

Defendant pled guilty to one count of mail fraud and was sentenced to 8 years and 9 months of imprisonment, as well as ordered to pay restitution to his victims. Defendant appealed. The court held that defendant could challenge the application of the vulnerable victim enhancement but, under the due deference standard, the court upheld the enhancement where it was reasonable for the district court to conclude that the combination of the victims' characteristics made them particularly susceptible to defendant's fraud. The court remanded defendant's ineffective-assistance claim that his trial counsel made errors relating to the amount-of-loss calculation because it required further factual development. Finally, the court remanded to the district court to correct the specific amounts of restitution owed to each of defendant's victim so that the amounts added up to total $3,646,747.83. View "United States v. Fareri" on Justia Law

Plaintiff filed a complaint against the District of Columbia and others regarding the pretrial conditions of his confinement. The District agreed that the the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a), requirement did not apply to plaintiff but urged the court to affirm the grant of summary judgment on his federal claims for failure to exhaust. The court joined its sister circuits and held that the PLRA exhaustion requirement did not apply because plaintiff was not a "prisoner" at the time he filed his complaint. Summary judgment was therefore inappropriately granted on his federal claims. As to his intentional infliction of emotional distress (IIED) claim, the court held that it had been abandoned because neither plaintiff's proposed amended complaint nor amicus brief, which he adopted, referenced that claim, and his pro se appellate brief provided no argument why the dismissal should be reversed. Accordingly, the court reversed in part and remanded plaintiff's federal claims to the district court. The court otherwise affirmed the judgment. View "Lesesne v. Doe, et al" on Justia Law

Indiana Boxcar, a holding company that owns several railroads, petitioned for review of the Board's determination that Indiana Boxcar was an "employer" for purposes of the Railroad Retirement Act and the Railroad Unemployment Insurance Act, 45 U.S.C. 231, 351. To be an employer under those two Acts, a company such as Indiana Boxcar must be "under common control" with a railroad. Before this case, the Board repeatedly held that parent corporations like Indiana Boxcar were not under common control with their railroad subsidiaries. Under Board precedent, the term "common control" did not usually apply to two companies in a parent-subsidiary relationship. Here, however, the Board did not adhere to that precedent and did not reasonably explain and justify its deviation from its precedent. Therefore, the court held that the Board's decision was arbitrary and capricious under the Administrative Procedure Act, 5 U.S.C. 706(2)(A). Accordingly, the court vacated and remanded to the Board. View "Indiana Boxcar Corp. v. RRRB" on Justia Law

Appellants challenged the IRS's deficiency finding, as well as an accuracy-related penalty. On appeal, appellants argued that the Tax Court misunderstood relevant law when it affirmed the IRS's calculation of their remaining basis in their S corporation. They also challenged the factual basis for the Tax Court's decisions affirming the Service's rejection of their over-reporting claim and upholding its imposition of the penalty. The court rejected defendant's first challenge, concluding that a shareholder's basis was decreased "for any period" by the amount of that shareholder's pro rata share of the corporation's losses, and a shareholder incurred previously unabsorbed losses in the first year the shareholder had adequate basis to do so. In regards to the over-reporting claim, the court held that the Tax Court made no clear error when it upheld the IRS's determination not to reduce the sole proprietorship's income. Consequently, there was no dispute that appellants' 2003 tax return understated their taxes by an amount that qualified as substantial. Accordingly, the court affirmed the judgment. View "Barnes, et al v. Commissioner, IRS" on Justia Law

Plaintiff sued his employer, Fannie Mae, alleging violations of federal anti-discrimination laws by denying him a salary increase for discriminatory reasons; maintaining a racially hostile work environment; and retaliating against him for filing a discrimination complaint. The district court granted Fannie Mae summary judgment. The court concluded that a reasonable jury could find that Fannie Mae unlawfully discriminated against, harassed, and retaliated against plaintiff. Therefore, plaintiff was entitled to a trial on those claims. Accordingly, the court reversed the district court's grant of summary judgment on all of plaintiff's anti-discrimination claims. The court affirmed the district court's grant of summary judgment with respect to plaintiff's D.C. law defamation claim because the statements at issue were not false. View "Ayissi-Etoh v. Fannie Mae, et al" on Justia Law

This case stemmed from CREW's Freedom of Information Act (FOIA), 5 U.S.C. 552, request to the FEC seeking several categories of records, including certain correspondence, calendars, agendas, and schedules of the Commissioners. At issue was when must a FOIA requester exhaust administrative appeal remedies before suing in federal district court to challenge an agency's failure to produce requested documents. The exhaustion issue in this case boiled down to what kind of agency response qualified as a "determination." The court held that, in order to make a "determination" within the statutory time periods and thereby trigger the administrative exhaustion requirement, the agency need not actually produce the documents within the relevant time period. But the agency must at least indicate within the relevant time period the scope of the documents its will produce and the exemptions it will claim with respect to any withheld documents. In this case, the FEC did not make such a "determination" and CREW was not required to exhaust administrative appeal remedies before filing its FOIA suit. Accordingly, the court reversed the contrary judgment of the district court and remanded for further proceedings. View "Citizens for Resp. and Ethics v. FEC" on Justia Law