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

Plaintiff filed suit against two police officers, alleging that they violated the Fourth Amendment and D.C. law because each officer assaulted her son and one killed him. The court concluded that there are genuine issues of material fact with respect to the actions of the officer who fired the fatal shots, thus making himself the only surviving eyewitness to the actual killing. Therefore, the court reversed the district court’s grant of summary judgment in his favor. The court affirmed the jury's verdict for the second officer. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Flythe v. District of Columbia" on Justia Law

Plaintiff filed suit against Whole Foods, alleging mistreatment that amounted to discrimination based on his disability and his race. Plaintiff suffers from a cognitive disability due to traumatic brain injury. He alleged that Whole Foods employees mistreated him and eventually orchestrated his false arrest for theft and trespassing. The court dismissed the suit. The court concluded, however, that plaintiff's pleadings set out allegations sufficient to survive dismissal of his Americans with Disabilities Act (ADA), 42 U.S.C. 12182(a), claim. The court held plaintiff's Civil Rights Act of 1964 (CRA), 42 U.S.C. 2000a(a), claim in abeyance until he complies with the CRA notice provision. Accordingly, the court reversed the dismissal of both the ADA and CRA claims and remanded for further proceedings. View "Brown v. Whole Foods" on Justia Law

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

Section 308(1) of the Immigration and Nationality Act of 1952, 8 U.S.C. § 1408(1), designates persons born in American Samoa as non-citizen nationals. Plaintiffs, individuals born in the United States territory of American Samoa, challenged section 308(1), as well as State Department policies and practices implementing the statute on Citizenship Clause grounds and under the Administrative Procedure Act, 5 U.S.C. 500 et seq. The district court dismissed the case for failure to state a claim upon which relief can be granted. On appeal, plaintiffs reassert their constitutional claim. The court concluded that, while the language of the Thirteenth Amendment may be broader than that found in the Citizenship Clause, this comparison yields no dispositive insight as to whether the Citizenship Clause’s use of the term “United States” includes American Samoa or similarly situated territories. Even assuming a background context grounded in principles of jus soli, the court is skeptical that the framers plainly intended to extend birthright citizenship to distinct, significantly self-governing political territories within the United States’s sphere of sovereignty - even where, as is the case with American Samoa, ultimate governance remains statutorily vested with the United States Government. The court held it anomalous to impose citizenship over the objections of the American Samoan people themselves, as expressed through their democratically elected representatives. Accordingly, the court affirmed the judgment. View "Tuaua v. United States" on Justia Law

PLN filed a Freedom of Information Act (FOIA), 5 U.S.C. 552 et seq., request to the Bureau seeking all documents showing money the Bureau paid in connection with lawsuits and claims brought against it between January 1, 1996, and July 31, 2003. The Bureau subsequently withheld information pursuant to exemption 6 and 7(C) of FOIA. The district court granted summary judgment in favor of the Bureau. The court reversed, agreeing with PLN that the Bureau’s use of a categorical explanation for the redactions was improper because of the varied nature of the documents and of the individuals shielded from disclosure, and that the district court did not adequately balance the privacy and public interests at stake. Accordingly, the court reversed the district court’s grant of summary judgment and remand for further proceedings View "Prison Legal News v. Samuels" on Justia Law

Petitioners seek review of EPA's final rule, which determined that supercritical carbon dioxide injected into Class VI underground wells for purposes of geologic sequestration is “solid waste” within the meaning of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6903(27). The court dismissed the petitions for review because petitioners lacked Article III standing. In this case, neither Southern nor Occidental can show any injury sufficient to satisfy the requirements of Article III; Carbon Sequestration Council lacks standing because Southern lacks standing; and American Petroleum Institute lacks standing because Occidental lacks standing. View "Carbon Sequestration Council v. EPA" on Justia Law

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

Appellants, four associations involved in building and developing land, challenged consent decrees that require the Service to determine, in accordance with a settlement-defined schedule for action, whether 251 species should be listed as endangered or threatened. The court concluded that appellants lacked Article III standing, rejecting their claims of procedural injuries based on loss of opportunity to comment at the warranted-but-precluded stage, withdrawal of the warranted-but-precluded classification, and acceleration of final listing determinations. Appellants failed to allege a cognizable harm and appellants' members cannot show injury. Accordingly, the court affirmed the district court's dismissal. View "Nat'l Ass'n of Home Builders v. U.S. Fish & Wildlife" on Justia Law

Plaintiff filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., seeking an order requiring DCPS to provide her son with compensatory education. The district court dismissed the suit as moot because the school system responded to the complaint by offering an individualized education plan that is adequate to keep the child on track going forward. The court concluded, however, that the district court failed to address whether the child was entitled to compensatory education, which is a remedy that remains available. Accordingly, the court reversed the judgment of the district court and remanded for further proceedings. View "Boose v. District of Columbia" on Justia Law

Defendants challenged a district court order requiring that they add two statements to their cigarette packages and advertisements: an announcement that a federal court has ruled that they “deliberately deceived the American public” about the dangers of cigarettes; and a declaration that they “intentionally designed cigarettes” to maximize addiction. The court concluded that given its earlier decisions in this case, the manufacturers’ objection to disclosing that they intentionally designed cigarettes to ensure addiction is both waived and foreclosed by the law of the case. Those decisions make equally clear that the district court, in ordering defendants to announce that they deliberately deceived the public, exceeded its authority under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-1968, to craft remedies that “prevent and restrain” future violations. 18 U.S.C. 1964(a). The court affirmed in part, reversed in part, and remanded for further proceedings. View "United States v. Philip Morris USA Inc." on Justia Law