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

Andres Cabezas was arrested in an FBI sting operation in 2017 and later pled guilty to receipt of child pornography. While his appeal was pending, he submitted FOIA requests to the FBI for records related to his case. After six months without a response, Cabezas filed a lawsuit in the U.S. District Court for the District of Columbia, seeking the release of the requested records. The FBI eventually released some records but withheld others, citing various FOIA exemptions. The district court granted summary judgment to the FBI, finding that it had conducted a reasonable search and properly withheld documents under FOIA and the Privacy Act.Cabezas appealed the district court's decision, challenging the adequacy of the FBI's search and the justification for withholding records. He also contested the denial of his motions for limited discovery and in camera review. The U.S. Court of Appeals for the District of Columbia Circuit reviewed the case de novo and found that the FBI had made a good faith effort to conduct a reasonable search, using appropriate methods and search terms. The court also found that the FBI's affidavits provided a detailed account of the search process and the reasons for withholding certain records.The Court of Appeals affirmed the district court's judgment, agreeing that the FBI had conducted a reasonable search and properly invoked FOIA exemptions to withhold certain records. The court also upheld the denial of Cabezas's motions for limited discovery and in camera review, finding no abuse of discretion. The court concluded that Cabezas had not provided sufficient evidence to challenge the adequacy of the FBI's search or the validity of the exemptions claimed. View "Cabezas v. FBI" on Justia Law

In February 2021, a severe cold snap hit the central United States, causing widespread power outages and fatalities. This event highlighted the need for improved grid reliability. The Midcontinent Independent System Operator (MISO), which manages the electrical grid in the region, proposed changes to its capacity market to address these issues. MISO's new system includes seasonal capacity markets, a revised method for calculating generator capacity, and new rules for generator outages. The Federal Energy Regulatory Commission (FERC) approved these changes.Entergy Arkansas, LLC, along with other companies, petitioned for review of FERC's approval, arguing that FERC acted arbitrarily and capriciously. Entergy challenged three main aspects: the new method for calculating generator capacity, the requirement for generator owners to replace capacity if offline for more than 31 days in a season, and the 120-day notice requirement for planned outages. Entergy was supported by several intervenors, including public utilities commissions and the East Texas Electric Cooperative.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that FERC had adequately explained its approval of MISO's changes. FERC's reliance on a study showing the new methodology's accuracy was deemed reasonable. The court also upheld the 31-day capacity replacement rule and the 120-day notice requirement, finding that FERC had provided sufficient rationale for these rules. The court denied Entergy's petitions for review and did not address issues raised solely by the intervenors. The court concluded that FERC's decisions were not arbitrary or capricious and were supported by substantial evidence. View "Entergy Arkansas, LLC v. FERC" on Justia Law

Federal agents seized packages containing noncompliant plant and animal products shipped to Amazon fulfillment centers in the U.S. by overseas sellers. The Department of Agriculture concluded that Amazon, by providing its fulfillment services, had aided, abetted, caused, or induced the unlawful importation of these products and imposed a $1 million fine on Amazon.The case was initially reviewed by an administrative law judge (ALJ) who granted summary judgment in favor of the Department, finding that Amazon had unlawfully imported the products by aiding, abetting, causing, or inducing their importation. The ALJ rejected Amazon's argument that it was unaware of the sellers' noncompliance, stating that neither bad intent nor any mens rea was required for liability. The Judicial Officer of the Department affirmed the ALJ's decision, concluding that Amazon's conduct fell within the scope of the statutes and that Amazon had substantially assisted the importations with knowledge.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and set aside the Department's order. The court held that civil aiding-and-abetting liability generally requires conscious and culpable participation in unlawful conduct. The Plant Protection Act and Animal Health Protection Act incorporate this understanding. The court found that Amazon's provision of a neutral fulfillment service did not amount to conscious and culpable participation in the sellers' wrongdoing. Therefore, the court granted Amazon's petition for review, vacated the Department's order, and remanded the case for further proceedings consistent with its opinion. View "Amazon Services LLC v. AGRI" on Justia Law

Aly Abdellatif, an Egyptian citizen, suspected he was placed on government watchlists after experiencing unwarranted airport security screenings. He sought correction through the Transportation Security Administration's (TSA) redress program, which responded without confirming or denying his watchlist status. Abdellatif and his wife, Nina Araujo, petitioned for review, challenging the administration of the traveler redress program and their treatment during travel.The petitioners initially filed their case in the United States Court of Appeals for the District of Columbia Circuit. They named multiple federal agencies and officials as respondents, alleging that Abdellatif's inclusion on the Selectee List and TSA watchlists led to enhanced security screenings and secondary inspections. They argued that TSA's redress process failed to correct erroneous information, violating statutory obligations and due process rights. The court dismissed the petition against all respondents except TSA, citing jurisdictional limitations.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed the petition in part for lack of standing, as TSA cannot remove names from the Selectee List, which is maintained by the Terrorist Screening Center (TSC). The court found that petitioners' injuries related to the Selectee List were not redressable in this lawsuit. However, the court denied the remaining claims on the merits, concluding that TSA's redress process complies with statutory requirements and does not violate due process. The court also rejected the Fourth Amendment claims, finding that the enhanced security screenings and secondary inspections described were reasonable and did not constitute unreasonable searches or seizures. The petition was dismissed in part and otherwise denied. View "Abdellatif v. DHS" on Justia Law

The Federal Energy Regulatory Commission (FERC) is responsible for ensuring that rates charged by interstate oil pipelines are just and reasonable. Every five years, FERC reviews the methodology, known as the Index, used to set maximum annual rate increases. In 2020, FERC conducted its five-year review and set a new Index level, which was later modified on rehearing without adhering to notice-and-comment procedures.Initially, FERC invited comments on the proposed Index, receiving input from both pipeline operators (Carriers) and customers (Shippers). FERC issued an Initial Order in December 2020, establishing an Index level higher than proposed, effective July 1, 2021. Both Carriers and Shippers sought rehearing, with Carriers requesting minor changes and Shippers challenging the Index level. FERC issued a Rehearing Order in January 2022, adopting Shippers' suggestions and setting a new, lower Index effective March 1, 2022. Shippers sought clarification on the retroactive application of the Rehearing Order, which FERC denied.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. Carriers argued that FERC failed to comply with the Administrative Procedure Act (APA) by modifying the Index without notice-and-comment procedures. The court agreed, noting that once the Initial Order's Index became effective on July 1, 2021, any substantive changes required adherence to APA procedures. The court found that FERC's modification of the Index in the Rehearing Order without such procedures was improper.The court granted Carriers' petitions for review, vacated the Rehearing Order, and ordered FERC to reinstate the Initial Order. Shippers' petitions for review were dismissed as moot due to the vacatur of the Rehearing Order. View "Liquid Energy Pipeline Association v. FERC" on Justia Law

Hudson Transmission Partners, a merchant transmission facility, previously held firm rights to draw electricity from the PJM grid and was assessed costs for certain grid improvements. In 2017, Hudson relinquished its firm rights, leading to a dispute over whether it must continue paying for previously assessed costs for lower voltage facility upgrades and economic projects under the PJM Open Access Transmission Tariff.The Federal Energy Regulatory Commission (FERC) found that Hudson must continue to pay these costs. FERC determined that the PJM Tariff dictates that prior assessments for lower voltage facility upgrades are fixed and unaffected by a change in firm rights. Additionally, the costs of economic projects are validly allocated to entities like Hudson that benefit from the energy savings, regardless of their firm rights status.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld FERC's decision, agreeing that Hudson remains responsible for the previously assessed costs. The court noted that the PJM Tariff includes a saving clause that fixes the cost responsibility for lower voltage facilities unless explicitly changed, which was not the case here. The court also found that Hudson continues to benefit from the economic projects, justifying the continued cost responsibility.The court concluded that FERC's interpretation of the PJM Tariff was consistent with its prior orders and the cost-causation principle, which assigns costs based on the burdens imposed or benefits received by a party. Therefore, the court denied the petitions for review, affirming that Hudson must continue to pay the previously assessed costs for the lower voltage facility upgrades and economic projects. View "New York Power Authority v. FERC" on Justia Law

A group of hospitals challenged a rule by the Department of Health and Human Services (HHS) that adjusted Medicare reimbursement rates. HHS had increased reimbursements for hospitals in the lowest wage quartile and decreased them for others to maintain budget neutrality. The hospitals argued that this adjustment exceeded HHS's statutory authority under the Medicare Act.The United States District Court for the District of Columbia ruled in favor of the hospitals, finding that HHS lacked the authority to make such adjustments. However, the court did not vacate the rule but remanded it to HHS with instructions to recalculate the reimbursements.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and agreed with the lower court that HHS exceeded its authority. The court held that the Medicare Act's wage-index provision did not allow HHS to deviate from the congressionally prescribed formula. The adjustments provision also did not grant HHS the power to override the specific statutory formula. The court concluded that HHS's action must be vacated, not just remanded. Additionally, the court directed that the hospitals should receive an award of interest on the recalculated reimbursements as required by the Medicare statute.The court affirmed in part, reversed in part, and remanded the case to the district court for further proceedings consistent with its opinion. View "Bridgeport Hospital v. Becerra" on Justia Law

The Environmental Protection Agency (EPA) updated its regulations to ensure that the transportation fuel mix in the United States contains the required amounts of renewable fuel. The new regulations specifically address biogas-derived renewable fuel, implementing a more structured process to prevent fraud and error. The Coalition for Renewable Natural Gas, representing industry stakeholders, petitioned to overturn these changes, arguing that the new rules were too rigid and burdensome.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The Coalition argued that the EPA lacked authority to regulate biogas producers and that the new requirements were arbitrary and capricious. They also claimed procedural violations in the rulemaking process. The EPA defended its regulations, stating that they were necessary to ensure compliance with renewable fuel standards and to prevent fraud and double counting.The Court of Appeals found that the EPA acted within its authority under the Clean Air Act to regulate biogas producers and that the new rules were reasonable and supported by substantial evidence. The court also held that the EPA had followed proper procedures in adopting the rule. The court denied the Coalition's petition for review, upholding the EPA's updated regulations. The main holding was that the EPA's modifications to the biogas-derived renewable fuel regulations were reasonable and necessary to ensure compliance with renewable fuel standards and to prevent fraud. View "Coalition for Renewable Natural Gas v. EPA" on Justia Law

Tenaska Clear Creek Wind, LLC ("Clear Creek") sought to generate wind energy for sale in parts of Missouri, southeast Iowa, and northeast Oklahoma. Clear Creek challenged the Federal Energy Regulatory Commission's (FERC) decision to allow Southwest Power Pool, Inc. (SPP) to assign over $100 million in upgrade costs to Clear Creek for its wind turbine project. Clear Creek argued that FERC's decision was arbitrary, capricious, and contrary to precedent.Initially, Clear Creek submitted an interconnection request to Associated Electric Cooperative, Inc. (AECI) and requested Network Resource Interconnection Service (NRIS). AECI identified SPP and Midcontinent Independent System Operator, Inc. (MISO) as potentially affected systems. SPP conducted several studies, initially estimating upgrade costs at $31.2 million, which later fluctuated significantly. Clear Creek began construction based on initial studies but faced a restudy by SPP, which increased the estimated costs to $763 million, later adjusted to $102 million. Clear Creek filed a complaint with FERC, which partially granted and partially denied the complaint, requiring SPP to restudy the project using updated models. The restudy resulted in $88 million in upgrade costs.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld FERC's orders, finding that SPP's methodology for assigning upgrade costs was consistent with the "but for" cost allocation principle and not arbitrary or capricious. The court also found that Clear Creek's downgrade to Energy Resource Interconnection Service (ERIS) did not moot the case, as Clear Creek retained the right to re-open the matter if it prevailed. The court concluded that FERC's decision was based on reasoned decision-making and substantial evidence, denying Clear Creek's petitions for review. View "Tenaska Clear Creek Wind, LLC v. FERC" on Justia Law

In late 2003, Wye Oak Technology, Inc., a small American company, entered into a contract with the Iraqi Ministry of Defense to rebuild Iraq’s military. Wye Oak performed under the contract for nearly five months, but Iraq refused to pay and instead gave the money to another party. When Wye Oak’s owner traveled to Iraq to resolve the payment issue, he was killed by unidentified assailants. Wye Oak eventually ceased operations in Iraq and later sued Iraq in a U.S. federal district court for breach of contract.The United States District Court for the District of Columbia found Iraq liable after a bench trial and awarded Wye Oak over $120 million in damages. The court initially held that it had jurisdiction under the Foreign Sovereign Immunities Act (FSIA) based on the commercial exception’s second clause. However, the United States Court of Appeals for the District of Columbia Circuit vacated this judgment, ruling that the second clause did not apply and remanded the case to determine if the third clause of the commercial exception applied. On remand, the district court found that Iraq’s breach had direct effects in the United States, thus reentering its damages order.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and concluded that Iraq’s breach did not cause a direct effect in the United States as required by the FSIA’s commercial exception. The court noted that the contract and its breach were centered in Iraq, and any effects in the United States were too attenuated or involved intervening elements. Consequently, the court held that Iraq was immune from suit, vacated the district court’s judgment, and remanded the case with instructions to dismiss. View "Wye Oak Technology, Inc. v. Republic of Iraq" on Justia Law