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

Articles Posted in Civil Procedure
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Dalton Trucking and ARTBA challenged the EPA's final decision authorizing California regulations intended to reduce emissions of particulate matter and oxides of nitrogen from in-use nonroad diesel engines. Dalton Truck sought review of the same EPA decision at the same time in the Ninth Circuit, where ARTBA intervened in Dalton Trucking's behalf. Before this court, Dalton Trucking and ARTBA argue that the Ninth Circuit is the proper venue for their challenges and seek dismissal or transfer of their petitions for review. The court agreed that, pursuant to section 307(b)(1) of the Clean Air Act, 42 U.S.C. 7607(b)(1), venue is not proper in this court because EPA’s decision does not satisfy either of the statutory avenues for filing in the D.C. Circuit. Accordingly, the court dismissed the petitions for review. View "Dalton Trucking, Inc. v. EPA" on Justia Law

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The District and the Police Department appealed from the district court's grant of preliminary injunction restraining enforcement of a “good reason” standard in the D.C. Code provision governing the issuance of licenses for the carrying of concealed weapons, D.C. Law 20-279, 3(b). The court noted that the controlling fact in this case is the identity of the judge who decided it in the district court – The Honorable Senior United States District Judge Frederick J. Scullin, Jr., of the Northern District of New York. Although Judge Scullin served under a properly issued designation, that designation was limited to specific and enumerated cases. The court concluded that the present litigation is not one of those cases. The court concluded that, like the designated judge in Frad v. Kelly, Judge Scullin had a limited designation that did not extend beyond the specifications of that designation. Accordingly, the court vacated the order based on jurisdictional grounds. View "Wrenn v. District of Columbia" on Justia Law

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The Secretary issued regulations setting out reasonable cost limits (RCLs) for specified medical services and establishing certain exceptions to those limits. Canonsburg claimed that the Secretary has violated the Administrative Procedure Act (APA), 5 U.S.C. 551 et seq., because her method of calculation is inconsistent with governing regulations and was promulgated without notice and comment. In light of Canonsburg I, the district court granted the Secretary’s motion for summary judgment, concluding that issue preclusion barred Canonsburg’s suit. The court concluded that the Secretary did not waive her issue preclusion affirmative defense by not raising it at the administrative stage. Moreover, the Secretary asserted it, expressly and properly, in district court and the court is free to affirm the district court's application of the doctrine to Canonsburg's complaint. In light of the Supreme Court's plain language in SEC v. Chenery Corp. (Chenery I and II), the court's own construction of the Chenery doctrine and no persuasive case law to the contrary, the court concluded that the Chenery doctrine does not prohibit raising issue preclusion as an affirmative defense in district court even if the party raising the defense was not a party to the administrative proceeding or was otherwise unable to assert the defense at the administrative stage. Finally, the court rejected Canonsburg's claims of equitable considerations. Accordingly, the court affirmed the judgment. View "Canonsburg General Hosp. v. Burwell" on Justia Law

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Texas appealed the district court’s award of attorneys’ fees to three intervenors in Texas’s lawsuit under Section 5 of the Voting Rights Act, 52 U.S.C. 10304. Rejecting Texas’s cursory “Advisory” argument, the district court granted the motions and awarded fees. The district court held that Texas had conceded virtually all of the issues relevant to the motions for attorneys’ fees by deliberately choosing not to address them. The court affirmed the district court's judgment because "the discretion to enforce this rule lies wholly with the district court," and Texas forfeited any challenge to the district court’s exercise of that discretion by failing to even mention the issue in its opening brief in this court. View "State of Texas v. United States" on Justia Law

Posted in: Civil Procedure
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Appellees, medical records coders employed by appellants, filed suit against appellants for unlawfully failing to pay overtime pay. Appellees prevailed in a jury verdict and the district court denied appellants' motions for judgment as a matter of law, for a new trial, and to alter or amend the judgment. The court concluded that the jury fulfilled its function by considering conflicting evidence, resolving factual disputes, and returning a verdict. In this case, there is no reason for the court to upset that verdict or order a new trial. Because the court found no merit in appellants' arguments, the court affirmed the judgment of the district court. View "Radtke v. Caschetta" on Justia Law

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Plaintiff is the mother of Karl Grimes, a juvenile who was allegedly beaten to death at a detention facility. Plaintiff claimed that the District showed deliberate indifference to, and reckless disregard for, her son’s safety, and that the District was negligent in hiring, training, and supervising its employees at the detention center in violation of District of Columbia tort law, the Eighth Amendment, and 42 U.S.C. 1983. The district court granted the government’s motion for summary judgment, and denied as moot plaintiff’s cross-motion to strike the summary judgment motion and to disqualify the Attorney General of the District of Columbia based on an asserted conflict of interest. The court concluded that the district court should resolve a motion to disqualify counsel before it turns to the merits of any dispositive motion because a claim of counsel’s conflict of interest calls into question the integrity of the process in which the allegedly conflicted counsel participates. Therefore, the court concluded that the district court erred in the sequence in which it rendered its decisions. Accordingly, the court vacated the district court's grant of summary judgment and its denial of the motion to disqualify, and remanded for further proceedings. View "Grimes v. District of Columbia" on Justia Law

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The underlying suit alleges that the District does not provide adequate opportunity for community-based care to the District’s Medicaid beneficiaries who are currently receiving long-term care in nursing homes. Petitioner seeks permission to file an interlocutory appeal challenging the district court's decision to certify the class. The court concluded that the District has not met its burden under the grounds for review it invoked to show “manifest error” by the District Court. Accordingly, the court denied the petition to permit an appeal of class certification and the court did not not reach the merits of the District’s substantive claims of error. View "In Re: District of Columbia" on Justia Law

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The Secretaries appealed the grant of summary judgment and issuance of a mandatory injunction to sell a certain amount of timber annually from federal land managed under the Oregon and California Railroad and Coos Bay Wagon Road Grant Lands Act of 1937, 43 U.S.C. 1181a et seq. The court concluded that none of the plaintiff timber companies or timber organizations have demonstrated Article III standing. The declarations that the companies submitted before judgment fail to establish Article III standing for any plaintiff. None of the organizational plaintiffs identify individual injured members. The declarations are speculative with respect to the claimed threat to plaintiffs’ interests and conclusory or silent with respect to their claims of causation and redressibility. Accordingly, the court vacated the judgment and remanded with instructions to dismiss the complaint. View "Swanson Group Mfg. v. Jewell" on Justia Law

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Crossroads GPS, the beneficiary of a favorable decision by the Commission, moved to intervene as a defendant in a suit challenging the Commission’s ruling. The district court denied intervention, finding Crossroads’ interests were aligned with the FEC’s Office of General Counsel’s, which was defending the ruling. The court concluded that Crossroads has Article III standing because it has a concrete stake in the favorable agency action currently in place. The court rejected the Commission's argument that prudential standing prevents the court from hearing this case, because Crossroads' interest do not fall within the zone of interests the law protects, where the zone of interest has no applicability to an intervening defendant in this instance. The court further concluded that Crossroads easily met the minimal burden of showing inadequacy of representation and should be allowed to intervene as of right. Accordingly, the court reversed the judgment of the district court. View "Public Citizen v. FEC" on Justia Law

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After Abu Wa’el (Jihad) Dhiab, a detainee at Guantanamo Bay, went on a hunger strike, he was forcibly extracted from his cell and force-fed. The district court examined 32 classified videotapes of Dhiab's forcible cell extractions and force-feedings in order to grant Dhiab's motion to enjoin the government from forcibly extracting him from his cell and force-feeding him. At issue is the district court's grant of media organizations' motion to unseal and release the videotapes. The court concluded that, the district court’s decision did not terminate the action, and it does not qualify as an immediately appealable collateral order. Therefore, the court lacked jurisdiction. Further, this case does not present the extraordinary circumstances required for mandamus relief. Accordingly, the court dismissed the appeal for lack of jurisdiction and denied the request for a writ of mandamus View "Dhiab v. Obama" on Justia Law