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

Linda Martin filed a class action lawsuit against the FBI, alleging that the Notice of Seizure provided to property owners did not meet the Due Process requirements under the Fifth Amendment. The FBI had seized $40,200 from Martin's safe deposit box and issued a Notice of Seizure, which Martin claimed lacked specific legal or factual bases for the seizure, thus denying her a meaningful opportunity to respond. Martin sought declaratory and injunctive relief for herself and a proposed nationwide class of individuals who had received similar notices.The United States District Court for the District of Columbia dismissed Martin's individual claim as moot after the FBI returned her seized property. The court also dismissed the class action for failure to exhaust administrative remedies and for failure to state a plausible Due Process claim. The court found that Martin had an adequate opportunity to present her Due Process challenge during the administrative proceedings and that her claim was moot because the FBI had returned her property.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the district court's dismissal of Martin's individual claim as moot, as the FBI had returned her property. The court also dismissed the appeal of the class certification judgment for lack of jurisdiction, noting that Martin had not challenged the denial of class certification in her appellate briefs. The court concluded that without a certified class, it lacked jurisdiction to review the district court's merits rulings on the Due Process and exhaustion claims. View "Martin v. FBI" on Justia Law

Eight citizens of Mali alleged that, as children, they were trafficked to Côte d’Ivoire and forced to work without pay on small, remote cocoa farms. After eventually returning to Mali, they brought a putative class action in the United States against seven major cocoa importers, claiming the companies violated the Trafficking Victims Protection Reauthorization Act (TVPRA) by knowingly benefiting from a supply chain that relied on forced child labor. The plaintiffs asserted that the importers orchestrated and controlled a cocoa supply chain “venture” and delayed meaningful action against child labor through their leadership of the World Cocoa Foundation.The United States District Court for the District of Columbia dismissed the complaint for lack of standing. The court found that the plaintiffs failed to connect the defendants to any specific cocoa plantations, including those where the plaintiffs had worked. The court concluded that the plaintiffs’ general, industry-wide allegations lacked the specificity required to establish causation under Article III of the Constitution. The plaintiffs appealed, and the United States Court of Appeals for the District of Columbia Circuit held the appeal in abeyance pending resolution of a similar case, Doe 1 v. Apple Inc.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiffs lacked Article III standing because they did not plausibly allege facts showing a causal connection between their forced labor and the importers’ conduct. Specifically, the complaint failed to allege that the importers sourced cocoa, directly or through intermediaries, from the specific farms where the plaintiffs worked. The court distinguished this case from Doe 1 v. Apple Inc., where plaintiffs had plausibly traced their injuries to the defendants’ suppliers. The dismissal was affirmed. View "Coubaly v. Cargill Incorporated" on Justia Law

Adam Steele and Krystal Comer, tax return preparers, challenged the IRS's requirement to obtain or renew a Preparer Tax Identification Number (PTIN) by completing Form W-12, which involves paying a fee and disclosing personal information. They initially joined a class action in 2014 contesting the IRS's authority to impose these fees and the amount of information required by Form W-12. However, class counsel later withdrew these claims. Steele and Comer then attempted to revive these claims in a separate lawsuit.The United States District Court for the District of Columbia dismissed their complaint, citing the rule against claim-splitting, which prevents duplicative litigation between the same parties asserting the same claims, even without a final judgment in the first case. The district court found that Steele and Comer had already raised and then withdrawn these claims in the ongoing class action and were denied leave to amend the complaint to reassert them.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal. The appellate court held that the Paperwork Reduction Act (PRA) does not bar judicial review of the IRS's authority to demand information through Form W-12, but the rule against claim-splitting still precludes the plaintiffs' suit. The court emphasized that claim-splitting bars duplicative litigation filed before final judgment and that Steele and Comer had a fair opportunity to litigate their claims in the earlier class action. The court concluded that the district court's dismissal was proper to prevent strategic end runs around procedural rulings and to preserve the integrity of the adjudicative process. View "Steele v. United States" on Justia Law

The Bureau of Land Management (BLM) approved over 4,000 permits for oil and gas wells on public land in New Mexico and Wyoming from January 2021 to August 2022. Environmental organizations challenged these permits, alleging that BLM failed to adequately consider the climate and environmental justice impacts of the wells. The district court dismissed the claims, holding that the plaintiffs lacked standing.The plaintiffs appealed, asserting standing based on affidavits from their members who live, work, and recreate near the drilling sites, claiming injuries to their health, safety, and recreational and aesthetic interests. They also claimed standing based on the wells' overall contribution to global climate change and an organizational injury from the government's failure to publicize information about climate change.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the plaintiffs failed to sufficiently link their alleged harms to the specific agency actions they sought to reverse. The court emphasized that plaintiffs must demonstrate standing for each challenged permit by showing a concrete and particularized injury that is fairly traceable to the challenged action and likely to be redressed by a favorable ruling. The court found that the plaintiffs' generalized claims about the harms of oil and gas development were insufficient to establish standing for the specific permits at issue.The court also rejected the plaintiffs' claims of organizational standing, finding that the alleged injuries were limited to issue advocacy and did not demonstrate a concrete and demonstrable injury to the organization's activities. Consequently, the court affirmed the district court's judgment of dismissal. View "Center for Biological Diversity v. Department of the Interior" on Justia Law

Darian McKinney, a health and physical education teacher, was employed by the District of Columbia Public Schools (DCPS) for four years. During his tenure, he was investigated for sexual harassment, leading to a grievance he filed against DCPS. Both disputes were resolved through a Settlement Agreement, under which McKinney resigned but was allowed to reapply for teaching positions. However, when he reapplied, DCPS blocked his return, citing a failed background check.McKinney sued the District of Columbia, alleging that DCPS breached the Settlement Agreement by not fairly considering his employment applications and deprived him of property and liberty without due process. The United States District Court for the District of Columbia dismissed his complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Settlement Agreement did not obligate DCPS to fairly consider McKinney’s applications, only to allow him to apply. The court found no basis in the contract’s language or law for McKinney’s demand for fair consideration. Additionally, the court ruled that McKinney did not have a constitutionally protected property interest in his original job, the contingent job offers, or his eligibility for DCPS positions. The court also found that McKinney’s claim of deprivation of liberty without due process was forfeited as it was not raised in the lower court.The court affirmed the district court’s dismissal of McKinney’s complaint. View "Darian McKinney v. DC" on Justia Law

Dr. John Doe, a federal public servant with a security clearance, was convicted of two felonies in Ohio in the early 1990s. He received a pardon from the Ohio governor in 2009, and his felony convictions were sealed by an Ohio court. In 2022, Dr. Doe applied for a position at the Federal Deposit Insurance Corporation (FDIC), but his application was denied due to a statutory bar against hiring individuals with felony convictions. Dr. Doe then filed a lawsuit challenging the constitutionality of this hiring prohibition and sought to proceed under a pseudonym to avoid public association with his sealed convictions.The United States District Court for the District of Columbia denied Dr. Doe's motion to proceed under a pseudonym. The court acknowledged Dr. Doe's privacy concerns and the lack of unfairness to the government but concluded that the privacy interest in felony convictions does not warrant pseudonymity. The court emphasized the importance of transparency in judicial proceedings, especially in cases involving constitutional challenges against the government.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Dr. Doe's privacy interest in his sealed felony convictions was insufficient to overcome the presumption against pseudonymous litigation. The court highlighted the public's significant interest in open judicial proceedings, particularly when the case involves a constitutional challenge to a federal statute. The court found that the district court did not abuse its discretion in applying the relevant factors and denying Dr. Doe's motion to proceed under a pseudonym. View "Doe v. McKernan" on Justia Law

N.S. was arrested for robbery and destruction of property and was released on his own recognizance by a Magistrate Judge. However, before he could leave the courthouse, U.S. Marshals detained him based on an ICE detainer. N.S. filed a class complaint alleging that the Marshals acted beyond their statutory authority by making a civil immigration arrest, violating the Administrative Procedure Act.The United States District Court for the District of Columbia certified the proposed class and granted N.S.'s request for a permanent injunction, prohibiting Marshal Dixon and his agents from arresting and detaining criminal defendants in the Superior Court for suspected civil immigration violations. The court held that the Marshals were not authorized to make civil immigration arrests as they had not undergone the required training. The court also found that the 2002 Order delegating authority to the Marshals lacked sufficient legal support.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Marshals were not authorized to make civil immigration arrests due to the lack of required training. However, the court found that the class-wide injunction issued by the district court was barred by 8 U.S.C. § 1252(f)(1), which prohibits lower courts from enjoining the operation of certain immigration provisions. The court vacated the injunction and remanded the case to the district court to reconsider the appropriate remedy. View "N.S. v. Dixon" on Justia Law

MCS Industries, Inc. (MCS), a shipper, filed a complaint with the Federal Maritime Commission (FMC) against MSC Mediterranean Shipping Company S.A. (Mediterranean), alleging violations of the Shipping Act of 1984. MCS claimed that Mediterranean failed to provide agreed cargo space, forced MCS to pay higher rates on the spot market during the Covid-19 pandemic, refused to deal with MCS, discriminated against shippers at certain ports, and engaged in unreasonable business practices. Mediterranean initially provided some discovery material but later refused further requests, citing jurisdictional issues and Swiss law restrictions on document production.The Administrative Law Judge (ALJ) ordered Mediterranean to comply with discovery requests, but Mediterranean continued to resist, arguing that the FMC lacked jurisdiction and that Swiss law precluded compliance. After multiple warnings and attempts to resolve the discovery issue, including a failed Hague Convention request, the ALJ issued a default judgment against Mediterranean, ordering it to pay reparations to MCS. The FMC affirmed the default judgment, remanding only to recalculate reparations and consider sanctions for delay.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the FMC had jurisdiction over the complaint, as the allegations involved violations of the Shipping Act, not merely breach of contract claims. The court also found that the FMC did not abuse its discretion in issuing a default judgment. The court noted that Mediterranean's refusal to comply with discovery orders prejudiced MCS, burdened the FMC, and undermined the authority of the Commission. The court denied Mediterranean's petitions for review, affirming the FMC's decision. View "MSC Mediterranean Shipping Company S.A. v. Federal Maritime Commission" on Justia Law

Seven District of Columbia citizen-voters filed a complaint challenging the constitutionality of the Local Resident Voting Rights Amendment Act of 2022, which allows noncitizens to vote in municipal elections. The plaintiffs argued that this law dilutes their votes, discriminates against U.S. citizens, and violates the constitutional right to citizen self-government. The District of Columbia Board of Elections, responsible for implementing the law, was named as the defendant.The case was initially brought in D.C. Superior Court, but the Board removed it to the United States District Court for the District of Columbia. The Board then moved to dismiss the case, arguing that the plaintiffs lacked standing and failed to state a claim. The district court agreed with the Board, holding that the plaintiffs did not demonstrate any individual disadvantage and thus lacked standing. The court dismissed the complaint, characterizing the plaintiffs' grievances as generalized and insufficient to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the plaintiffs had standing to sue because they alleged a concrete and particularized injury: the dilution of their votes due to the expansion of the electorate to include noncitizens. The court distinguished this case from others where plaintiffs failed to show individualized harm. The court found that the plaintiffs' claims were specific to their voting power in D.C. local elections and not merely a generalized grievance. Consequently, the court reversed the district court's dismissal and remanded the case for further proceedings. The Board's cross-appeal was dismissed as moot. View "Hall v. District of Columbia Board of Elections" on Justia Law

Junius Joyner, III, an African-American male, was hired by a legal staffing agency, Mestel & Company (Hire Counsel), and assigned to work at Morrison & Foerster LLP in Washington, D.C. He worked on the merger of Sprint Corporation with T-Mobile U.S., Inc. from July to December 2019. Joyner alleged several incidents of racial discrimination and a hostile work environment, including delayed work assignments, derogatory comments, and harassment by coworkers. He also claimed wrongful discharge under D.C. law, asserting he was terminated after reporting potential antitrust violations.The United States District Court for the District of Columbia dismissed Joyner’s complaint for failure to state a claim. The court found that Joyner did not provide sufficient facts to support his claims of racial discrimination and a hostile work environment under 42 U.S.C. § 1981 and Title VII. The court also dismissed his wrongful discharge claim under D.C. law, concluding that it lacked supplemental jurisdiction over this state law claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court affirmed the district court’s dismissal of Joyner’s federal claims, agreeing that Joyner failed to plausibly allege that his treatment was racially motivated or that the work environment was sufficiently hostile. The court found that Joyner’s allegations did not meet the necessary standard to infer racial discrimination or a hostile work environment. However, the appellate court vacated the district court’s judgment on the wrongful discharge claim, holding that the district court lacked jurisdiction over this claim and remanded it with instructions to dismiss for lack of jurisdiction. View "Joyner v. Morrison and Foerster LLP" on Justia Law