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

David O’Connell filed a class action lawsuit against the United States Conference of Catholic Bishops (USCCB) for fraudulent solicitation of donations. O’Connell alleged that USCCB misled donors about the use of funds collected through the Peter’s Pence Collection, which were purportedly for emergency assistance but were instead used for investments and other purposes. O’Connell claimed that if he had known the true use of the funds, he would not have donated.The United States District Court for the District of Columbia denied USCCB’s motion to dismiss the case, which was based on the church autonomy doctrine. The District Court found that O’Connell’s claims raised a secular dispute that could be resolved using neutral principles of law, without delving into religious doctrine. The court emphasized that it would not address purely religious questions if they arose during litigation.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed USCCB’s appeal for lack of jurisdiction, stating that the collateral order doctrine did not apply. The court held that the church autonomy defense could be adequately reviewed on appeal after a final judgment, and that the denial of the motion to dismiss was not conclusive or separate from the merits of the case. The court emphasized that the church autonomy doctrine does not provide immunity from suit but serves as a defense to liability. The appeal was dismissed, and the case was remanded to the District Court for further proceedings. View "O'Connell v. United States Conference of Catholic Bishops" on Justia Law

Accuracy in Media (AIM) filed a Freedom of Information Act (FOIA) request with the Central Intelligence Agency (CIA) seeking records about American service members who were prisoners of war (POWs) or missing in action (MIA) from the Vietnam War and potentially still alive in Laos or Vietnam. The CIA conducted a search using specific terms but did not find any responsive records. AIM challenged the adequacy of the CIA's search, arguing that the search terms were insufficient.The United States District Court for the District of Columbia granted summary judgment in favor of the CIA, concluding that the search terms used by the CIA were reasonably likely to yield the requested records if they existed. The court also noted that the plaintiffs' evidence did not significantly suggest that the requested files were in the CIA's current operational files.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and found that the CIA's search terms were inadequate. The court noted that the search terms omitted key terms such as "Laos," "live sighting," "imagery," "reconnaissance," and "rescue," which were relevant to the FOIA request. The court also found that the CIA did not adequately explain why certain terms were used and others were omitted. The court held that the CIA failed to show beyond material doubt that its search was reasonably calculated to uncover all relevant documents.The Court of Appeals reversed the district court's grant of summary judgment to the CIA and remanded the case for further proceedings consistent with its opinion, requiring the CIA to either conduct a new search or provide a supplemental affidavit with adequate search terms and explanations. View "Hall v. CIA" on Justia Law

Samuel Shanks and Taylor Lambert, former employees of the International Union of Bricklayers & Allied Craftworkers, filed pro se lawsuits against the Union alleging discrimination. Shanks, who worked in accounting for over twenty years, claimed discrimination based on disability, race, color, and sexual orientation, as well as a hostile work environment and retaliation. Lambert, his niece, alleged wrongful termination, retaliation, and discrimination based on race, religion, and gender. Both claimed violations of various civil rights laws, including the D.C. Human Rights Act, the Americans with Disabilities Act, and Title VII of the Civil Rights Act of 1964.The Union removed the cases to the United States District Court for the District of Columbia, which dismissed the complaints for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). Shanks and Lambert appealed the dismissals. The United States Court of Appeals for the District of Columbia Circuit affirmed the dismissals in part but appointed amicus curiae to present arguments in favor of claims that were not suited for summary dismissal.The D.C. Circuit reviewed the district court’s dismissal de novo and concluded that the allegations of racial discrimination related to the Union’s COVID-19 vaccination policy were plausible. The court found that the Union’s two-stage roll-out of the policy disproportionately affected Black employees, who were given less time and fewer resources to comply with the vaccination mandate. The court held that the disparate impact and discriminatory treatment claims based on race were sufficiently pled to survive a motion to dismiss. The court affirmed the dismissal of other claims, including those based on sexual orientation, gender, and religion, as well as Shanks’ hostile work environment claim. The case was remanded to the district court for further proceedings on the racial discrimination claims. View "Shanks v. International Union of Bricklayers and Allied Craftworkers" on Justia Law

Fahmi Ahmed Moharam, a dual United States-Yemeni citizen, frequently travels between the two countries. In 2017, he was denied boarding a flight from Saudi Arabia to the U.S. and learned through the Transportation Security Administration (TSA) redress process that he was on the No Fly List. The government provided minimal information, citing national security concerns, and stated that his designation was based on his activities in Yemen from 2011 to 2017. After petitioning for review, the government informed him that he was no longer on the No Fly List and would not be relisted based on the currently available information.The TSA is mandated by statute to identify individuals who may pose a threat to civil aviation or national security and prevent them from boarding aircraft. The TSA also manages the Department of Homeland Security (DHS) Traveler Redress Inquiry Program (TRIP), which allows individuals to appeal their inclusion on the No Fly List. Moharam appealed through TRIP and was initially informed that he was on the list due to concerns about his activities in Yemen. Despite his requests for more information and administrative review, the TSA maintained his status on the list until the government later removed him.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that Moharam's removal from the No Fly List rendered his petitions for review moot, as the court could no longer provide effective relief. The court noted that the government’s assurance that Moharam would not be relisted based on the same information addressed the issue of potential recurrence. Consequently, the court dismissed the petitions for lack of jurisdiction, as the relief sought was no longer redressable. View "Moharam v. TSA" on Justia Law

Entergy companies petitioned for review of three orders by the Federal Energy Regulatory Commission (FERC). FERC had rejected tariff changes proposed by Midcontinent Independent System Operator (MISO), arguing that the new tariff would grant Entergy excessive market power. Entergy contended that FERC’s decisions were arbitrary and capricious.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. Entergy’s opening brief did not address the issue of standing, which is a jurisdictional prerequisite. This omission violated Circuit Rule 28(a)(7), which requires petitioners to set forth the basis for their claim of standing in their opening brief. As a result, Entergy forfeited any arguments in support of standing.The D.C. Circuit Court dismissed the petitions for review, stating that Entergy lacked standing. The court emphasized that Entergy’s failure to discuss standing in its opening brief constituted a forfeiture of the argument. Even if the court were to consider the standing arguments Entergy later advanced, the company did not demonstrate the necessary concrete, imminent, and redressable injury. The court concluded that dismissal was the appropriate consequence for Entergy’s failure to establish standing. View "Entergy Arkansas, LLC v. FERC" 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

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

Petitioners sought review of the Federal Energy Regulatory Commission's (FERC) grant of an abandonment incentive to ITC Midwest, LLC (ITC). This incentive allows ITC to recover 100% of its prudently incurred costs if a planned transmission project is abandoned for reasons beyond its control. Petitioners, a group of organizations whose members purchase electricity, argued that ITC's ownership of the project was uncertain due to ongoing litigation challenging the Iowa Right of First Refusal statute.The Federal Energy Regulatory Commission approved ITC's request for the abandonment incentive, finding that the project met the necessary criteria, including enhancing reliability and reducing congestion. Petitioners filed a protest, which FERC rejected, stating that regulatory or litigation uncertainty does not preclude granting an abandonment incentive. Petitioners then sought rehearing, which FERC also denied, reiterating that the approval was consistent with its precedent.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court determined that petitioners lacked Article III standing because they failed to show imminent injury from FERC's orders. The court noted that petitioners' claims of potential future higher rates were speculative and not concrete or imminent. The court also found that petitioners' interest in the proper application of the law and potential collateral estoppel effects did not constitute a cognizable injury. Consequently, the court dismissed the petition for lack of jurisdiction. View "Industrial Energy Consumers of America v. FERC" on Justia Law

Howard University’s Board of Trustees amended the institution’s bylaws to remove trustee positions that had been filled by alumni, students, and faculty for several decades. A group of alumni sued the University and the Board in D.C. Superior Court, seeking a declaration that the Board’s amendment was ultra vires because it violated the governing bylaws. Howard removed the case to federal court, arguing that the governance dispute hinged on the University’s federal charter. The alumni moved to remand the case back to state court.The United States District Court for the District of Columbia denied the alumni’s motion to remand, holding that the suit implicated a significant federal issue under Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing. The District Court then granted Howard’s motion to dismiss the case under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the District Court erred in exercising jurisdiction. The Court of Appeals determined that the case did not arise under federal law nor present a significant, disputed federal issue under Grable. Consequently, the Court of Appeals reversed the District Court’s decision and remanded the case with instructions to dismiss it without prejudice for lack of subject matter jurisdiction. View "Jenkins v. Howard University" on Justia Law