Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries
Articles Posted in Government & Administrative Law
Climate United Fund v. Citibank, N.A.
The Environmental Protection Agency (EPA) awarded $16 billion in grants to five nonprofit organizations to support the reduction of greenhouse gas emissions, as part of a larger $27 billion congressional appropriation under the Inflation Reduction Act. The grants were structured through agreements between the nonprofits and EPA, with Citibank acting as a financial agent to hold and disburse the funds. After concerns arose regarding conflicts of interest, lack of oversight, and last-minute amendments to the grant agreements, EPA terminated the grants in early 2025. Citibank, following an FBI recommendation, froze the accounts associated with the grants. The nonprofits sued, seeking to prevent the termination and to restore access to the funds.The United States District Court for the District of Columbia granted a preliminary injunction, ordering EPA and Citibank to continue funding the grants. The district court found it had jurisdiction, concluding the plaintiffs’ claims were not essentially contractual and thus did not need to be brought in the Court of Federal Claims. The court determined the plaintiffs were likely to succeed on their constitutional, regulatory, and arbitrary and capricious claims, and that the balance of harms and public interest favored the injunction.On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the district court abused its discretion in issuing the injunction. The appellate court found that the plaintiffs’ regulatory and arbitrary and capricious claims were essentially contractual, meaning jurisdiction lay exclusively in the Court of Federal Claims, not the district court. The court also held that the constitutional claim was meritless. The equities and public interest, the appellate court concluded, favored the government’s need for oversight and management of public funds. Accordingly, the D.C. Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Climate United Fund v. Citibank, N.A." on Justia Law
Healthy Gulf v. Department of the Interior
The case concerns a challenge to the United States Department of the Interior’s approval of the 2024–2029 National Outer Continental Shelf Oil and Gas Leasing Program, which authorizes up to three lease sales in the Gulf of Mexico region. Environmental organizations argued that the Department failed to adequately assess the risks to vulnerable coastal communities, did not properly consider the endangered Rice’s whale in its environmental sensitivity analysis, overlooked potential conflicts with other ocean uses, and did not sufficiently balance the program’s projected benefits against its environmental costs. The Department, in coordination with the Bureau of Ocean Energy Management, had developed the program through a multi-year process involving public comment and environmental review.After the Department finalized the program, the environmental groups and the American Petroleum Institute (API) each petitioned for review in the United States Court of Appeals for the District of Columbia Circuit. API later withdrew its petition but remained as an intervenor. The environmental petitioners sought to have the program remanded for further consideration, arguing violations of the Outer Continental Shelf Lands Act (OCSLA). The Department and API contested the petitioners’ standing and the merits of their claims.The United States Court of Appeals for the District of Columbia Circuit held that the environmental petitioners had associational standing to pursue their claims. On the merits, the court found that the Department of the Interior had satisfied OCSLA’s requirements by reasonably evaluating environmental justice concerns, the selection of representative species for environmental sensitivity analysis, and potential conflicts with other uses of the Gulf. The court concluded that the Department’s decision-making process was reasoned and not arbitrary or capricious. Accordingly, the court denied the petition for review, leaving the 2024–2029 leasing program in effect. View "Healthy Gulf v. Department of the Interior" on Justia Law
New Mexico Cattle Growers’ Association v. FWS
The case centers on the southwestern willow flycatcher, a bird listed as an endangered subspecies by the United States Fish and Wildlife Service since 1995. The New Mexico Cattle Growers’ Association petitioned the Service to remove the bird from the endangered species list, arguing that it is not a valid subspecies and thus does not qualify for protection under the Endangered Species Act. Their petition relied heavily on a 2015 scientific article by Robert Zink, which critiqued previous studies supporting the subspecies classification. The Service conducted a thorough review, including public comment and expert consultation, and ultimately reaffirmed the subspecies designation, finding that the best available scientific evidence supported its continued listing.The United States District Court for the District of Columbia reviewed the Service’s decision after the Cattle Growers filed suit, claiming the agency’s determination was arbitrary and capricious under the Administrative Procedure Act. The district court granted summary judgment in favor of the Service and its intervenors, the Center for Biological Diversity and the Maricopa Audubon Society, finding that the Service had reasonably explained its reliance on scientific studies and its application of the non-clinal geographic variation standard to determine subspecies validity.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s summary judgment de novo. The appellate court held that the Service’s decision was neither arbitrary nor capricious, as it was based on a reasonable and well-explained evaluation of scientific evidence. The court rejected the Cattle Growers’ arguments regarding the indeterminacy of the non-clinal geographic variation standard and found no merit in claims of constitutional or procedural deficiencies. The judgment of the district court was affirmed. View "New Mexico Cattle Growers' Association v. FWS" on Justia Law
Posted in:
Environmental Law, Government & Administrative Law
Newman v. Moore
Judge Pauline Newman, a sitting judge on the United States Court of Appeals for the Federal Circuit, was investigated by a Special Committee of her circuit under the Judicial Councils Reform and Judicial Conduct and Disability Act of 1980. The investigation was initiated after the Chief Judge of the Federal Circuit raised concerns about Judge Newman’s ability to manage her workload due to alleged health and age-related impairments. The Special Committee requested that Judge Newman undergo medical examinations and provide medical records, which she refused, arguing the requests and investigation were unlawful. As a result, the Federal Circuit’s Judicial Council suspended Judge Newman from receiving new case assignments for one year, with the suspension subsequently renewed.Judge Newman filed suit in the United States District Court for the District of Columbia, challenging her suspension on statutory and constitutional grounds. She argued that the Judicial Council exceeded its statutory authority, violated her due process rights by not transferring the matter to another circuit, and that the Act’s case-suspension provision was unconstitutional both facially and as applied. The district court dismissed her statutory and as-applied constitutional claims for lack of jurisdiction, relying on circuit precedent, and rejected her facial constitutional challenge on the merits.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s judgment. The court held that, under binding precedent from McBryde v. Committee to Review Circuit Council Conduct & Disability Orders of the Judicial Conference of the United States, it lacked jurisdiction to review Judge Newman’s statutory and as-applied constitutional claims. The court further held that Judge Newman’s facial constitutional challenge to the Act’s case-suspension provision failed because the provision has many constitutional applications. The judgment of the district court was affirmed. View "Newman v. Moore" on Justia Law
Posted in:
Constitutional Law, Government & Administrative Law
City of Billings v. TSA
In 2020, the Transportation Security Administration (TSA) proposed a rule to address insider threats in airports, specifically targeting the risk that aviation workers with unescorted access to secured areas could facilitate the introduction of weapons or dangerous items onto aircraft. Instead of following the usual public notice-and-comment procedures required by the Administrative Procedure Act (APA), TSA provided notice and an opportunity to comment only to airport operators. The finalized rule, known as the National Amendment, required major airports to physically screen aviation workers entering certain secured areas and to acquire explosives-detection equipment. Noncompliance could result in civil enforcement actions by TSA.After TSA finalized the National Amendment in April 2023, various municipalities operating airports and a trade organization, Airport Council International-North America (ACI-NA), submitted timely requests for reconsideration, arguing that TSA lacked statutory authority, that the APA required public notice and comment, and that the rule unlawfully compelled local officials to implement a federal scheme. TSA denied all reconsideration requests, maintaining that its own regulations permitted it to amend airport security programs by providing notice and comment only to affected operators. The petitioners then sought review of TSA’s denial in the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit held that the National Amendment is a legislative rule subject to the APA’s notice-and-comment requirements, which TSA failed to follow. The court vacated the National Amendment but withheld its mandate, allowing TSA time to promulgate a procedurally proper rule or inform the court if no rule is needed. The court required TSA to submit periodic status reports until a final resolution. View "City of Billings v. TSA" on Justia Law
Posted in:
Government & Administrative Law, Transportation Law
Battle Creek Health System v. Kennedy
A group of hospitals challenged the calculation of their Medicare fractions for fiscal year 2007, which is a key component in determining eligibility and payment amounts under the Medicare disproportionate share hospital (DSH) adjustment. The DSH adjustment provides increased reimbursement to hospitals serving a high number of low-income patients. The hospitals disputed the inclusion of Medicare Part C beneficiaries in the Medicare fraction, arguing that this reduced their payments. After the Centers for Medicare and Medicaid Services (CMS) published the Medicare fractions, the hospitals appealed to the Provider Reimbursement Review Board, seeking review of the calculation before the final DSH adjustment was determined.The Provider Reimbursement Review Board dismissed the hospitals’ appeal for lack of jurisdiction, reasoning that a challenge could only be brought after the final determination of the DSH adjustment was made and reflected in the Notice of Program Reimbursement (NPR). The Board concluded that publication of the Medicare fraction alone did not constitute a “final determination” as required by statute. The hospitals then sought review in the United States District Court for the District of Columbia, which disagreed with the Board and held that the hospitals’ challenge could proceed, interpreting precedent to allow appeals at the stage of Medicare fraction publication.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and reversed the district court’s judgment. The court held that the Board lacked jurisdiction to hear the hospitals’ challenge prior to the issuance of the NPR, because only the NPR constitutes the Secretary’s “final determination as to the amount of the payment” under the relevant statutory provision. The court clarified that while some prospective payment system components may be appealed before the NPR, retrospective adjustments like the DSH adjustment require final settlement before an appeal is ripe. View "Battle Creek Health System v. Kennedy" on Justia Law
Posted in:
Government & Administrative Law, Health Law
Hill v. DOI
Members of the Crow Tribe who own trust allotments on the Crow Reservation challenged the loss of their historic water rights following the ratification of the Crow Tribe-Montana Compact and the Crow Tribe Water Rights Settlement Act. The Settlement Act, passed by Congress in 2010, codified a negotiated agreement among the Crow Tribe, the state of Montana, and the United States, which defined tribal water rights and provided substantial federal funding for water infrastructure. In exchange, the Tribe and allottees agreed to waive all other water rights claims. The Act required the Secretary of the Interior to publish a Statement of Findings certifying that certain conditions were met, which would trigger the waiver of prior water rights.After the Secretary published the Statement of Findings in June 2016—following a deadline extension agreed to by the Tribal Chairman and the Secretary—several allottees filed suit nearly six years later. They argued that the extension was invalid because, under the Crow Constitution, only the Tribal General Council or Legislature could authorize such an agreement. They also alleged that the Secretary’s action exceeded statutory authority, breached trust obligations, and violated their Fifth Amendment rights. The United States District Court for the District of Columbia dismissed the complaint for failure to state a claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the dismissal de novo. The court held that the Secretary’s publication of the Statement of Findings constituted final agency action reviewable under the Administrative Procedure Act, but found the Secretary reasonably relied on the Tribal Chairman’s authority to extend the deadline. The court further held that the Settlement Act created specific trust duties, but the plaintiffs failed to plausibly allege any breach. The court also concluded that the plaintiffs’ Fifth Amendment claims for takings, due process, and equal protection failed as a matter of law. The judgment of the district court was affirmed. View "Hill v. DOI" on Justia Law
National Treasury Employees Union v. Vought
The case concerns a series of actions taken by the leadership of the Consumer Financial Protection Bureau (CFPB) in early 2025, following a change in presidential administration. The new Acting Directors, first Scott Bessent and then Russell Vought, implemented measures to significantly downsize the agency. These included pausing most agency activities, terminating employees (including the Student Loan Ombudsman), canceling contracts, declining additional funding, moving to smaller headquarters, and requiring advance approval for agency work. Some statutorily required services were neglected during this period, though agency leadership later clarified that legally mandated work should continue.Several plaintiffs, including organizations representing CFPB employees and groups that use CFPB services, filed suit in the United States District Court for the District of Columbia. They alleged that the agency’s actions amounted to an unlawful attempt to “shut down” the CFPB, violating both statutory mandates and the separation of powers. The district court found that agency leadership had indeed decided to shut down the Bureau and issued a preliminary injunction. This injunction required the government to reinstate terminated employees, refrain from further firings except for cause, maintain certain services, and rescind contract terminations, among other measures.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the district court lacked jurisdiction over claims related to loss of employment, as such claims must proceed through the Civil Service Reform Act’s specialized review scheme. For the remaining plaintiffs, the court found that their claims did not challenge a final agency action reviewable under the Administrative Procedure Act (APA), nor did they present a constitutional claim reviewable in equity. The court concluded that the plaintiffs’ attempt to challenge an inferred, overarching decision to shut down the CFPB was not viable under the APA or in equity. Accordingly, the D.C. Circuit vacated the preliminary injunction and remanded the case. View "National Treasury Employees Union v. Vought" on Justia Law
Posted in:
Civil Procedure, Government & Administrative Law
Vanda Pharmaceuticals, Inc. v. FDA
A pharmaceutical company sought approval from the Food and Drug Administration (FDA) to market tasimelteon, a drug previously approved for a rare sleep disorder, as a treatment for jet lag. The company submitted results from several clinical trials, focusing on both objective sleep measures and subjective assessments of alertness and next-day functioning. The FDA’s Center for Drug Evaluation and Research issued a complete response letter indicating that the application did not provide substantial evidence of efficacy, particularly criticizing the measurement of next-day impairment and the tools used for subjective endpoints. The company engaged in further discussions and dispute resolution with the FDA, including proposing a narrower indication for approval, but these efforts were unsuccessful.After the FDA issued a formal notice of opportunity for a hearing (NOOH), the company requested a hearing and submitted expert declarations supporting the adequacy of its clinical evidence. The FDA ultimately denied both the application and the hearing request, finding no genuine and substantial issue of fact warranting a hearing. The company then petitioned the United States Court of Appeals for the District of Columbia Circuit for review, arguing that the FDA was required to hold a hearing, that material factual disputes existed, that the FDA’s decision-making was arbitrary and capricious, and that the final decision violated the Appointments Clause.The United States Court of Appeals for the District of Columbia Circuit held that the Food, Drug, and Cosmetic Act does not require the FDA to hold a hearing before denying every new drug application, but the agency must grant a hearing if there are material factual disputes. The court found that, in this case, the FDA’s refusal to hold a hearing was arbitrary and capricious because the company’s expert evidence created genuine disputes over the adequacy of the clinical trials. The court remanded the case to the FDA for further proceedings consistent with its opinion. View "Vanda Pharmaceuticals, Inc. v. FDA" on Justia Law
Global Health Council v. Trump
The case concerns the executive branch’s decision to freeze foreign aid funds that Congress had appropriated for fiscal year 2024. On January 20, 2025, the President issued an executive order directing the State Department and USAID to pause foreign assistance spending, pending a review of those programs. This led to the suspension or termination of thousands of grant awards and significant restructuring within the agencies. Organizations that were recipients of these funds, many of which relied heavily on such funding, challenged the executive order, arguing that the freeze unlawfully impounded funds that Congress had directed to be spent.The United States District Court for the District of Columbia initially granted a temporary restraining order, and later a preliminary injunction, against the executive branch (excluding the President personally). The district court found that the plaintiffs had standing due to financial harm, and that they were likely to succeed on their claims that the executive branch’s actions violated the separation of powers, the Take Care Clause, the Impoundment Control Act (ICA), the Anti-Deficiency Act, and the Administrative Procedure Act (APA). The court ordered the government to make available the full amount of appropriated funds.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and vacated the district court’s preliminary injunction. The appellate court held that the plaintiffs lacked a cause of action to pursue their claims. Specifically, it found that the plaintiffs could not bring a freestanding constitutional claim when the alleged violations were statutory in nature, that the ICA precludes APA review by private parties (reserving enforcement to the Comptroller General), and that the plaintiffs could not reframe their claims as ultra vires actions. The court concluded that, although the plaintiffs had standing, they were not entitled to the preliminary injunction because they were unlikely to succeed on the merits. View "Global Health Council v. Trump" on Justia Law
Posted in:
Constitutional Law, Government & Administrative Law