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

The case involves American Medical Response of Connecticut (AMR), a company that operates ambulances and employs emergency medical technicians and paramedics, and the International Association of EMTs and Paramedics (Union). The Union and AMR had a collective bargaining agreement that was in effect from 2019 through 2021. During the COVID-19 pandemic, AMR invoked an emergency provision in the agreement and cut shifts due to reduced demand. The Union raised concerns about AMR's actions and requested specific information from AMR to investigate potential grievances. AMR refused to provide some of the requested information, arguing that the emergency provision in the agreement excused it from providing the information during the pandemic. The Union filed a charge with the National Labor Relations Board (NLRB), alleging that AMR's refusal to provide the information violated the duty to bargain under the National Labor Relations Act (NLRA). The NLRB sided with the Union, and AMR sought review of this decision.The United States Court of Appeals for the District of Columbia Circuit disagreed with the NLRB's decision. The court held that the NLRB was required to determine whether the collective bargaining agreement relieved AMR of the duty to provide the requested information. The court explained that the NLRA requires the enforcement of collective bargaining agreements, including those provisions that limit a union's information rights. The court expressed that the NLRB had put the cart before the horse by concluding that AMR failed to provide information before determining whether AMR had a contractual duty to provide such information. As a result, the court granted AMR’s petition for review, denied the NLRB's cross-application for enforcement, vacated the NLRB's order, and remanded the case back to the NLRB for it to consider whether the collective bargaining agreement excused AMR from providing the requested information. View "American Medical Response of Connecticut, Inc. v. NLRB" on Justia Law

Kaboni Savage, a federal prisoner, brought a lawsuit against the U.S. Department of Justice arguing that the department was infringing upon his First Amendment rights by limiting his communication with family and friends. Savage claimed that the restrictions imposed under the Special Administrative Measures (SAMs) were unjust. However, Savage did not complete the Justice Department's Administrative Remedy Program (ARP), a process designed to seek relief from such restrictions. The United States District Court for the District of Columbia dismissed Savage's lawsuit, citing the Prison Litigation Reform Act of 1996 (PLRA), a law requiring prisoners to exhaust all available administrative remedies before bringing a lawsuit. The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's decision, stating that Savage did not fully pursue all available administrative remedies and hence, his lawsuit was barred under the PLRA. View "Savage v. DOJ" on Justia Law

The appellant, Hdeel Abdelhady, filed a suit against George Washington University ("the University") after being injured on the university's property. During the proceedings, the University submitted several exhibits that contained references to Abdelhady's private medical treatments and diagnoses. Abdelhady filed a motion to seal these exhibits to protect her medical privacy, but the District Court partially denied her motion. Abdelhady appealed this decision in the United States Court of Appeals for the District of Columbia Circuit.The appeals court first established its jurisdiction over the appeal by applying the "collateral order doctrine," which allows for immediate appeal of certain orders that are crucial and unreviewable after the final judgment. The court noted the high value of maintaining privacy in medical treatments and diagnoses and affirmed that an order denying a motion to seal records containing such information is immediately appealable.Turning to the merits of the appeal, the appeals court found that the District Court had erred in denying Abdelhady's motion to seal. It noted a lack of clarity in the District Court's decision and found that the lower court had relied on the incorrect assumption that Abdelhady had already disclosed in her redacted complaint all of the same information she sought to have sealed. The appeals court also found that the District Court did not adequately consider several factors that should guide such a decision, including the need for public access to the documents, Abdelhady's interest in medical privacy, and the extent of previous public access to the records.Consequently, the appeals court found that the District Court had abused its discretion and vacated the lower court's decision. The case was remanded back to the District Court for further consideration of all relevant factors and a more detailed explanation of its decision. The appeals court underscored that this remand did not imply that Abdelhady's motion to seal should have been granted in full, noting several ambiguities in her request. View "Abdelhady v. George Washington University" on Justia Law

The U.S. Court of Appeals for the District of Columbia Circuit ruled on an appeal by former President Donald J. Trump regarding his claim of presidential immunity from civil damages liability related to the January 6, 2021, Capitol riot. Plaintiffs included Capitol Police officers and members of Congress who alleged that Trump, through his actions and speech, incited the riot that resulted in physical injuries and emotional distress.The court determined that, at this stage in the proceedings, Trump has not demonstrated an entitlement to presidential immunity. It distinguished between actions carried out in a president’s official capacity, which are protected by immunity, and those carried out in a private or unofficial capacity, which are not. The court rejected Trump's argument that presidential speech on matters of public concern is always an official function, stating that such speech can be either official or unofficial depending on context.The court also rejected Trump's claim that his actions leading up to and on January 6 were official because they were under his Article II duty to "take Care that the Laws be faithfully executed," stating that this claim is not independent of his ability to show that he engaged in the relevant actions in his official capacity as President rather than his unofficial capacity as a presidential candidate.The court held that Trump's actions as alleged in the complaints, if proven to be true, were carried out in his capacity as a presidential candidate, not as the sitting President. Therefore, he is subject to civil suits like any private citizen. However, the court specified that Trump must be allowed to present facts and make arguments in the district court that his actions were taken in his official capacity. View "Blassingame v. Trump" on Justia Law

Representative Scott Perry’s cell phone, which was seized by the Federal Bureau of Investigation pursuant to a warrant. In a district court motion, Representative Perry argued the Clause bars the government from reviewing many of the messages stored on the phone. As to communications with Executive Branch officials and parties outside of Congress, Representative Perry argued that his messages are necessarily privileged because they constitute “informal factfinding”—a capacious category he asserts is always privileged and includes a Member’s attempts to obtain information related to topics of upcoming votes without express House authorization. The district court held none of these communications were privileged because they were “political” or not fact-finding at all. The DC Circuit stayed the district court’s order pending appeal and expedited the case.   The DC Circuit vacated the judgment in part and remanded. The court explained that as o Representative Perry’s communications with individuals outside the federal government, communications with members of the Executive Branch, and communications with other Members of Congress regarding alleged election fraud during the period before Congress’s vote certifying the 2020 election and before its vote on H.R. 1, the district court failed to apply the fact-specific privilege inquiry under Gravel. The court affirmed with respect to the remaining privilege determinations about Representative Perry’s communications with Members of Congress. View "In re: Sealed Case (PUBLIC REISSUED OPINION)" on Justia Law

The Securities and Exchange Commission recently approved the trading of two bitcoin futures funds on national exchanges but denied approval of Grayscale’s bitcoin fund. Petitioning for review of the Commission’s denial order, Grayscale maintains its proposed bitcoin exchange-traded product is materially similar to the bitcoin futures exchange-traded products and should have been approved to trade on NYSE Arca.   The DC Circuit vacated the order and granted Grayscale’s petition. The court explained that the denial of Grayscale’s proposal was arbitrary and capricious because the Commission failed to explain its different treatment of similar products. The court explained that to avoid arbitrariness and caprice, administrative adjudication must be consistent and predictable, following the basic principle that similar cases should be treated similarly. The court wrote that NYSE Arca presented substantial evidence that Grayscale is similar, across the relevant regulatory factors, to bitcoin futures ETPs. As such, the court found that the Commission failed to adequately explain why it approved the listing of two bitcoin futures ETPs but not Grayscale’s proposed bitcoin ETP. Accordingly, the court explained that in the absence of a coherent explanation, this, unlike regulatory treatment of like products, is unlawful. View "Grayscale Investments, LLC v. SEC" on Justia Law

In this case, the Federal Trade Commission appeals the district court’s dismissal of claims against pharmaceutical manufacturers for violations of Sections 1 and 2 of the Sherman Act. The district court dismissed the action against Appellees Endo Pharmaceuticals Inc. (Endo), its parent, Endo International plc (Endo International), Impax Laboratories, LLC (Impax), and its parent, Amneal Pharmaceuticals, Inc. (Amneal) (collectively Appellees) for failure to state a claim because a single patentee granting an exclusive license is conduct protected and allowed under the Patent Act. 35 U.S.C. 261;The D.C. Circuit affirmed the district court’s dismissal of the Commission’s claims. The court concluded that the resolution of the case came down to the following question: Does a valid patent holder’s grant of a nearly exclusive license to a single potential competitor in exchange for royalty payments violate antitrust law when that nearly exclusive license restrains trade only to an extent traditionally recognized by patent law as reasonable? The court answered the question in the negative, holding that under FTC v. Actavis, Inc., when a complaint alleges that a patent holder has violated the antitrust laws, courts must strike a balance “between the lawful restraint on trade of the patent monopoly and the illegal restraint prohibited broadly by the Sherman Act.” The Court must defer to Congress’ judgment, as outlined in the Patent Act. View "FTC v. Endo Pharmaceuticals Inc." on Justia Law

Plaintiff acting on behalf of her son, a student who qualifies for special education services under the Individuals with Disabilities Education Act (IDEA), appealed an order of the district court denying her motions for a temporary restraining order and a preliminary injunction pursuant to the IDEA’s “stay-put” provision. The stay-put provision provides that “during the pendency of any proceedings conducted pursuant to this section, unless the State or local educational agency and the parents otherwise agree,” a student “shall remain” in the student’s “then-current educational placement.   The DC Circuit affirmed. The court explained that Community Services for Autistic Adults and Children, a private residential treatment center in Maryland, and its affiliated school, the Community School of Maryland’s (together, CSAAC) unilateral decision to discharge Plaintiff’s son did not trigger the IDEA’s stay-put mandate because the District did not refuse to provide a similar available placement. Neither the text of Section 1415(j) nor the court’s previous decisions applying the provision impose an affirmative duty on the District to provide an alternative residential environment when a student’s then-current placement becomes unavailable for reasons outside the District’s control. The court explained that Plaintiff’s attempt to bring a substantive challenge on behalf of her son by invoking the stay-put mandate is procedurally improper because Section 1415(j) is not intended to afford parties affirmative relief, on the merits, in the form of an automatic injunction. View "Anne Davis v. DC" on Justia Law

The United States Maritime Administration (“MARAD”) approved a shipping company’s request to replace two vessels operating in the Pacific trade within the Maritime Security Program. Matson Navigation Co., a competitor in the Pacific, petitions for review of the replacements. As a source of jurisdiction, Matson points to the Hobbs Act, under which the DC Circuit had original jurisdiction over some acts of MARAD.   The DC Circuit reversed two orders of the district court, consolidated with these petitions, that held jurisdiction over Matson’s claims under the Administrative Procedure Act (“APA”) and was exclusive in the court of appeals. The court wrote that Matson was not a “party” to the replacement proceedings for either vessel, therefore, the court denied the petitions for direct review. The court explained that whether a case begins in district court or is eligible for direct review in the court is a policy decision that is for “Congress rather than us to determine.” The court wrote that as Matson’s counsel stated at oral argument, the company is just “trying to get review.” Because sending limited comments based on limited information to an informal agency proceeding does not confer “party” status under the Hobbs Act, that review starts in the district court. View "Matson Navigation Company, Inc. v. DOT" on Justia Law

The Environmental Protection Agency extended the deadline for compliance with a revised national drinking water regulation, which in turn extended the deadline for states to enforce conforming revisions to their own regulations. Five states seek to challenge the federal extension, which they say will cause them various harms.   The DC Circuit dismissed the petition for review for lack of Article III standing. The court explained that the states’ uncertainty also is not redressable in this litigation. Their harm is not knowing what future obligations they will face, making it difficult to plan. But the Delay Rule gives the states more time to hedge their bets. Setting it aside would worsen any problem of regulatory uncertainty, taking as a given EPA’s unreviewable decision to consider changes to the Revision Rule. View "State of Arizona v. EPA" on Justia Law