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

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

Abram J. Harris, a pro se plaintiff, sued the Federal Motor Carrier Safety Administration (FMCSA) of the U.S. Department of Transportation (DOT) in the D.C. Superior Court, alleging fraud and abuse of process. Harris claimed that a female employee he hired, who also worked for FMCSA, turned the agency against him after their working relationship soured. The Superior Court dismissed the case sua sponte for failure to state a claim, and Harris appealed to the D.C. Court of Appeals. Subsequently, the DOT removed the case to federal court.The United States District Court for the District of Columbia reviewed the case after removal. Harris did not object to the removal or seek remand to the Superior Court. The district court dismissed the case, concluding it lacked jurisdiction because Harris's claims fell outside the Federal Tort Claims Act’s limited waiver of sovereign immunity and because Harris had failed to exhaust administrative remedies. Alternatively, the court held that Harris had failed to state a claim. Harris timely appealed the dismissal as to DOT but not as to Assistant U.S. Attorney Stephanie Johnson, whom he had added as a defendant.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that under 28 U.S.C. § 1442(a), a federal defendant may remove a case from state appellate court to federal district court. The court also determined that Harris forfeited any arguments regarding procedural defects in the removal process by not objecting in the district court or moving for remand. Additionally, Harris forfeited any arguments that the district court erred in dismissing his case for lack of jurisdiction and failure to state a claim by failing to raise them in his briefs. Consequently, the appellate court affirmed the district court’s dismissal of the case. View "Harris v. Department of Transportation Federal Motor Carrier Safety Administration" 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

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

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

Jacquelyn N’Jai filed a lawsuit against the U.S. Department of Education, New York University (NYU), Long Island University (LIU), Immediate Credit Recovery, Inc. (ICR), and FMS Investment Corporation (FMS), alleging various violations of federal law. N’Jai claimed that she had repaid her student loans but was falsely certified for additional loans by a bank analyst, with NYU and LIU allegedly signing her name on fraudulent loan applications. She contended that the Department of Education and its debt collectors used unlawful practices to collect on these loans, including garnishing her tax refund and threatening to garnish her Social Security checks.The United States District Court for the District of Columbia dismissed N’Jai’s claims against LIU, NYU, ICR, and FMS for lack of personal jurisdiction, citing the government contacts exception. This exception prevents the assertion of personal jurisdiction based solely on a defendant’s contact with federal government agencies in the District of Columbia. The court dismissed the claims against the remaining defendants for other reasons.The United States Court of Appeals for the District of Columbia Circuit reviewed the case, focusing on whether the government contacts exception under D.C. law is limited to First Amendment activities. The court noted the ongoing uncertainty about the scope of this exception, referencing previous cases where the D.C. Court of Appeals had not definitively resolved whether the exception is confined to First Amendment activity. Due to this uncertainty, the appellate court certified two questions to the D.C. Court of Appeals: whether the government contacts exception is limited to First Amendment activity and, if so, whether the contacts alleged in this case fall under that exception. The appellate court did not make a final ruling on the personal jurisdiction issue, pending the D.C. Court of Appeals' response to the certified questions. View "N'Jai v. Department of Education" on Justia Law