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

Jose Vasquez was detained twice by the Metropolitan Police Department (MPD) because he shares the same name and birthdate as a wanted criminal. He sued the District of Columbia and an officer for constitutional violations under Section 1983, and the District alone for negligence, malicious prosecution, and false imprisonment. The District Court granted summary judgment on the Section 1983 and negligence claims. The jury found the District liable for false imprisonment but not for malicious prosecution, awarding Vasquez $100,000. However, the District Court later granted the District's motion for judgment as a matter of law, nullifying the jury's award, and alternatively granted a motion for remittitur.The United States District Court for the District of Columbia initially reviewed the case. It granted summary judgment in favor of the District and Officer Agosto on the Section 1983 claims, finding no constitutional violations. The court also dismissed the negligence claim. The jury trial on the common law claims resulted in a mixed verdict, with the jury awarding damages for false imprisonment but not for malicious prosecution. The District Court subsequently overturned the jury's verdict on false imprisonment and reduced the damages awarded.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. It affirmed the District Court's summary judgment on the Section 1983 claims, agreeing that there was no clearly established constitutional violation and that qualified immunity applied to Officer Agosto. However, the appellate court vacated the District Court's judgment as a matter of law and the alternative remittitur on the false imprisonment claim. The appellate court reinstated the jury's verdict and remanded for further proceedings, emphasizing that the jury could reasonably find that the differing social security numbers indicated Vasquez was not the wanted criminal, and that the jury's damages award was justified based on the emotional harm suffered. View "Vasquez v. District of Columbia" on Justia Law

The plaintiffs, Medicare beneficiaries with chronic illnesses, rely on home health aides for essential care. They allege that Medicare-enrolled providers have either refused to provide in-home care or offered fewer services than entitled, attributing this to the policies of the Secretary of Health and Human Services. They sought systemwide reforms through a lawsuit.The United States District Court for the District of Columbia dismissed the plaintiffs' complaint for lack of Article III standing. The court found that the plaintiffs failed to plausibly allege that their requested relief would redress any harm. The court noted that the injuries were caused by private home health agencies (HHAs) not before the court and that it was speculative whether enjoining the Secretary would change the HHAs' behavior. The court also found the plaintiffs' requested relief too general, making it difficult to evaluate its potential impact.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiffs failed to demonstrate redressability, a key component of standing. The court noted that the plaintiffs' injuries stemmed from the independent choices of private HHAs, and it was speculative that the requested injunctions would prompt these agencies to change their behavior. The court emphasized that the plaintiffs did not provide sufficient evidence to show that the Secretary's enforcement policies were a substantial factor in the HHAs' decisions. Consequently, the plaintiffs lacked standing to bring the suit, and the dismissal for lack of jurisdiction was affirmed. View "Johnson v. Becerra" on Justia Law

The case involves the Animal Legal Defense Fund (ALDF) challenging the U.S. Department of Agriculture's (USDA) approval of Perdue's "Fresh Line" chicken and turkey product labels. ALDF claimed that the labels, which depicted birds roaming outside, were misleading because the birds were raised indoors. ALDF requested the USDA to disapprove these labels, arguing that they misled consumers. The USDA declined, leading ALDF to sue, alleging violations of the Poultry Products Inspection Act (PPIA) and the Administrative Procedure Act (APA).The United States District Court for the District of Columbia dismissed ALDF's complaint, concluding that ALDF lacked standing to challenge the USDA's actions. The court found that ALDF failed to establish both organizational and associational standing. Specifically, the court determined that ALDF's member, Marie Mastracco, did not suffer a sufficiently concrete injury to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court agreed with the district court, finding that ALDF did not demonstrate that Mastracco faced an ongoing or imminent injury. The court noted that while Mastracco was misled by the labels in the past, she now knows the truth about the birds' living conditions, making any future reliance on the labels self-inflicted. Additionally, the court found that ALDF failed to show that other poultry-product labels with similar misleading graphics existed, which would be necessary to establish a substantial likelihood of future harm.The Court of Appeals affirmed the district court's dismissal of ALDF's complaint without prejudice, holding that ALDF lacked standing to pursue its claims. View "Animal Legal Defense Fund, Inc. v. Vilsack" on Justia Law

A member of the United Mine Workers of America arbitrated a dispute against Consol Energy, Inc. and won. The Union then sued to confirm the arbitration award, while Consol and its subsidiaries counterclaimed to vacate the award. The Union argued that the subsidiaries could not unilaterally reduce health benefits promised to miners for life, even if they no longer mined coal. Consol, which served as the health-plan administrator, had sent a letter indicating potential changes to benefits after the agreement expired, prompting the arbitration.The United States District Court for the District of Columbia dismissed the Union’s claim for lack of standing, reasoning that the Union was not injured as Consol had not actually modified the benefits. The court also declined to vacate the arbitration award on the merits of the Subsidiaries’ counterclaim. Both parties appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the Union’s claim did not fall under § 301(a) of the Labor Management Relations Act, which only authorizes suits for actual violations of contracts, not anticipated future violations. Consequently, the Union’s claim was dismissed for lack of subject-matter jurisdiction. Regarding the Subsidiaries’ counterclaim, the court determined that the Subsidiaries lacked standing as they were not named in the arbitration award and had not shown a concrete and imminent injury. The court vacated the district court’s orders on the Subsidiaries’ counterclaim and remanded it with instructions to dismiss for lack of standing.Thus, the appellate court affirmed the dismissal of the Union’s claim and vacated and remanded the Subsidiaries’ counterclaim for dismissal due to lack of standing. View "International Union, United Mine Workers of America v. Consol Energy Inc." on Justia Law

In 2017, Special Counsel Robert S. Mueller III began investigating Russian interference in the 2016 presidential election, during which Giorgi Rtskhiladze testified before a grand jury. When the Department of Justice (DOJ) released a redacted version of Mueller’s report, it included information that Rtskhiladze claimed was inaccurate and damaging to his reputation. Rtskhiladze sued for both equitable and monetary relief and sought a copy of his grand jury testimony transcript.The United States District Court for the District of Columbia ruled that Rtskhiladze lacked standing for his equitable claims, failed to state a claim for damages, and was not entitled to obtain a copy of the transcript. The court found that Rtskhiladze had abandoned his separate damages claim against DOJ and Mueller personally and forfeited arguments about this claim on appeal.The United States Court of Appeals for the District of Columbia Circuit held that Rtskhiladze has standing to bring all his claims and remanded the equitable claims for further consideration. The court agreed with the district court that Rtskhiladze failed to state a claim for damages under the Privacy Act, as he did not allege "intentional or willful" conduct by DOJ. The court also upheld the district court’s decision to deny Rtskhiladze’s request to obtain a copy of his grand jury testimony transcript, emphasizing the government’s interest in maintaining grand jury secrecy and preventing witness intimidation.In summary, the appellate court reversed the district court’s dismissal of Rtskhiladze’s equitable claims for lack of standing, affirmed the dismissal of his damages claim for failure to state a claim, and upheld the denial of his request to obtain a copy of his grand jury transcript. View "Rtskhiladze v. Mueller" on Justia Law

Eva Mae Givens applied for Medicaid assistance in Washington, D.C., but the District miscalculated her copay, requiring her to pay an extra $2,000 per month. Givens requested an administrative hearing to contest the miscalculation, but D.C. did not provide a timely hearing as required by federal law. Givens then filed a lawsuit under 42 U.S.C. § 1983, seeking injunctive and declaratory relief for a fair hearing and monetary damages for the overpayments. While the case was pending, D.C. held a hearing, corrected the miscalculation, and sent back-payments to the nursing homes, but not to Givens. Givens passed away shortly after the hearing.The United States District Court for the District of Columbia dismissed the case with prejudice, ruling that the claims were moot because D.C. had provided the hearing and corrected the miscalculation. The court also held that Givens failed to state a claim for relief. Givens' children, who sought to be substituted as plaintiffs, appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the dismissal of the fair-hearing claims as moot but noted that the dismissal should have been without prejudice. The court found that the calculation claim was not moot because Givens had not received compensation for the overpayments she made. However, the court held that the calculation claim failed to plausibly allege a violation of federal rights under § 1983, as Givens did not identify a specific municipal policy or custom that caused the miscalculation.The appellate court vacated the district court's order dismissing the case with prejudice and remanded the case. The district court was instructed to dismiss the moot fair-hearing claims without prejudice and to either dismiss the calculation claim without prejudice or provide a detailed explanation for a dismissal with prejudice. View "Givens v. Bowser" on Justia Law

In 2014, the Senate Select Committee on Intelligence released a report mentioning the CIA’s “operational control” over fourteen detainees transferred to Guantanamo Bay in September 2006. Based on this, a lawyer representing one of the detainees requested records from the CIA under the Freedom of Information Act (FOIA) about the CIA’s “operational control” at Guantanamo from September 2006 to January 2007. The CIA identified three documents but stated it could neither confirm nor deny the existence of other records, citing the need to protect classified intelligence sources and methods.The United States District Court for the District of Columbia granted summary judgment in favor of the CIA. The court concluded that the CIA had adequately justified its Glomar response, which allows an agency to refuse to confirm or deny the existence of records if doing so would reveal classified information. The court found that the CIA had not waived its right to issue a Glomar response despite the release of some documents and references in the Senate report.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that the CIA did not waive its Glomar response through official acknowledgment, as the Senate report and the released documents did not constitute an official acknowledgment by the CIA. The court also found that the CIA’s justification for its Glomar response was logical and plausible, as confirming or denying the existence of additional records could reveal protected intelligence sources and methods. The court affirmed the district court’s judgment in favor of the CIA. View "Connell v. CIA" on Justia Law

The Department of Homeland Security (DHS) issued a rule allowing certain H-4 visa holders, who are dependent spouses of H-1B visa holders, to work in the United States. Save Jobs USA challenged this rule, arguing that DHS exceeded its authority under the Immigration and Nationality Act (INA). The INA includes provisions that grant the Secretary of Homeland Security the power to set conditions for nonimmigrants' stay in the U.S. and to establish necessary regulations. DHS relied on these provisions to justify the rule.The United States District Court for the District of Columbia granted summary judgment in favor of DHS, citing the precedent set by the D.C. Circuit in Washington Alliance of Technology Workers v. DHS (Washtech). In Washtech, the court upheld a DHS rule allowing certain foreign students to work in the U.S. based on similar INA provisions. The district court found that Save Jobs USA did not meaningfully distinguish its case from Washtech and thus ruled in favor of DHS.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the INA provisions cited by DHS indeed grant the agency the authority to issue employment-related rules for nonimmigrants. The court noted that Save Jobs USA did not effectively challenge the applicability of the Washtech precedent. Additionally, the court rejected Save Jobs USA's argument that the major questions doctrine should apply, stating that Washtech had already interpreted the relevant statutory provisions post-West Virginia v. EPA. Therefore, the appellate court upheld the district court's summary judgment in favor of DHS. View "Save Jobs USA v. DHS" on Justia Law

Carol Lewis and Douglas Sargent, both diabetics and Medicare beneficiaries, sought reimbursement for continuous glucose monitors and related supplies from 2015 to 2017. After the Department of Health and Human Services (HHS) denied their claims, they pursued judicial review and sought to represent a class of individuals with similar claims. The district court denied their motion for class certification, noting that most putative class members had unexhausted or untimely claims. The court concluded that neither waiver of the exhaustion requirement nor equitable tolling of the limitations period was appropriate, reducing the putative class to seventeen individuals, which was too small to meet the numerosity requirement for class certification. After the Centers for Medicare & Medicaid Services (CMS) issued new guidance in 2022, the district court granted partial judgment in favor of Lewis and Sargent, setting aside the denials of their claims and declaring that continuous glucose monitors are durable medical equipment.Lewis and Sargent appealed the denial of class certification to the United States Court of Appeals for the District of Columbia Circuit. They did not challenge the favorable merits judgment but focused solely on the class certification issue. The Court of Appeals, however, dismissed their appeal for lack of constitutional standing. The court held that their desire to serve as class representatives did not create a cognizable Article III interest, as they did not allege any concrete individual injury resulting from the denial of class certification. The court emphasized that an abstract interest in representing a class is insufficient to satisfy the requirements of Article III standing. Consequently, the appeal was dismissed for lack of jurisdiction. View "Lewis v. Becerra" on Justia Law

In a dispute between the Republic of Djibouti and Doraleh Container Terminal (Doraleh), Doraleh secured a $474 million arbitral award against Djibouti. Djibouti then nationalized a majority interest in Doraleh and appointed a provisional administrator, Chantal Tadoral, to manage the company. Quinn Emanuel, a law firm, sought to enforce the arbitral award in the U.S. District Court for the District of Columbia, claiming to represent Doraleh. However, Tadoral stated she did not authorize the filing, and Djibouti requested the case be dismissed.The District Court for the District of Columbia entered judgment for Doraleh, holding that Quinn Emanuel’s authority was irrelevant or, alternatively, that Djibouti had forfeited the issue by not raising it during arbitration. Djibouti appealed, arguing that the district court erred by not determining whether Quinn Emanuel had the authority to represent Doraleh.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and disagreed with the district court. The appellate court held that Quinn Emanuel’s authority is relevant and that the issue of a lawyer’s authority can be challenged at any point in litigation. The court found that Djibouti presented substantial evidence questioning Quinn Emanuel’s authority, which required the district court to determine whether the law firm had the authority to file the suit. Consequently, the appellate court vacated the judgment and remanded the case to the district court to determine Quinn Emanuel’s authority to represent Doraleh. View "Doraleh Container Terminal SA v. Republic of Djibouti" on Justia Law