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

Jose Vasquez was detained twice by the Metropolitan Police Department (MPD) because he shares the same name and birthdate as a wanted criminal. He sued the District of Columbia and an officer for constitutional violations under Section 1983, and the District alone for negligence, malicious prosecution, and false imprisonment. The District Court granted summary judgment on the Section 1983 and negligence claims. The jury found the District liable for false imprisonment but not for malicious prosecution, awarding Vasquez $100,000. However, the District Court later granted the District's motion for judgment as a matter of law, nullifying the jury's award, and alternatively granted a motion for remittitur.The United States District Court for the District of Columbia initially reviewed the case. It granted summary judgment in favor of the District and Officer Agosto on the Section 1983 claims, finding no constitutional violations. The court also dismissed the negligence claim. The jury trial on the common law claims resulted in a mixed verdict, with the jury awarding damages for false imprisonment but not for malicious prosecution. The District Court subsequently overturned the jury's verdict on false imprisonment and reduced the damages awarded.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. It affirmed the District Court's summary judgment on the Section 1983 claims, agreeing that there was no clearly established constitutional violation and that qualified immunity applied to Officer Agosto. However, the appellate court vacated the District Court's judgment as a matter of law and the alternative remittitur on the false imprisonment claim. The appellate court reinstated the jury's verdict and remanded for further proceedings, emphasizing that the jury could reasonably find that the differing social security numbers indicated Vasquez was not the wanted criminal, and that the jury's damages award was justified based on the emotional harm suffered. View "Vasquez v. District of Columbia" on Justia Law

The case involves the Animal Legal Defense Fund (ALDF) challenging the U.S. Department of Agriculture's (USDA) approval of Perdue's "Fresh Line" chicken and turkey product labels. ALDF claimed that the labels, which depicted birds roaming outside, were misleading because the birds were raised indoors. ALDF requested the USDA to disapprove these labels, arguing that they misled consumers. The USDA declined, leading ALDF to sue, alleging violations of the Poultry Products Inspection Act (PPIA) and the Administrative Procedure Act (APA).The United States District Court for the District of Columbia dismissed ALDF's complaint, concluding that ALDF lacked standing to challenge the USDA's actions. The court found that ALDF failed to establish both organizational and associational standing. Specifically, the court determined that ALDF's member, Marie Mastracco, did not suffer a sufficiently concrete injury to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court agreed with the district court, finding that ALDF did not demonstrate that Mastracco faced an ongoing or imminent injury. The court noted that while Mastracco was misled by the labels in the past, she now knows the truth about the birds' living conditions, making any future reliance on the labels self-inflicted. Additionally, the court found that ALDF failed to show that other poultry-product labels with similar misleading graphics existed, which would be necessary to establish a substantial likelihood of future harm.The Court of Appeals affirmed the district court's dismissal of ALDF's complaint without prejudice, holding that ALDF lacked standing to pursue its claims. View "Animal Legal Defense Fund, Inc. v. Vilsack" on Justia Law

The plaintiffs, Medicare beneficiaries with chronic illnesses, rely on home health aides for essential care. They allege that Medicare-enrolled providers have either refused to provide in-home care or offered fewer services than entitled, attributing this to the policies of the Secretary of Health and Human Services. They sought systemwide reforms through a lawsuit.The United States District Court for the District of Columbia dismissed the plaintiffs' complaint for lack of Article III standing. The court found that the plaintiffs failed to plausibly allege that their requested relief would redress any harm. The court noted that the injuries were caused by private home health agencies (HHAs) not before the court and that it was speculative whether enjoining the Secretary would change the HHAs' behavior. The court also found the plaintiffs' requested relief too general, making it difficult to evaluate its potential impact.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiffs failed to demonstrate redressability, a key component of standing. The court noted that the plaintiffs' injuries stemmed from the independent choices of private HHAs, and it was speculative that the requested injunctions would prompt these agencies to change their behavior. The court emphasized that the plaintiffs did not provide sufficient evidence to show that the Secretary's enforcement policies were a substantial factor in the HHAs' decisions. Consequently, the plaintiffs lacked standing to bring the suit, and the dismissal for lack of jurisdiction was affirmed. View "Johnson v. Becerra" on Justia Law

In 2001, China and Nigeria signed a bilateral investment treaty to encourage investment between the two countries, agreeing to treat each other's investors fairly and protect their investments. Zhongshan Fucheng Industrial Investment, a Chinese company, invested in Nigeria by participating in a joint venture with Ogun State to develop a free-trade zone. After years of development and significant investment, Ogun State abruptly terminated its relationship with Zhongshan, and Nigerian federal authorities expelled the company's executives. Zhongshan initiated arbitration proceedings, and an arbitrator found that Nigeria had breached its obligations under the treaty, awarding Zhongshan over $55 million in damages.The United States District Court for the District of Columbia held that it had jurisdiction over the case, finding that the Foreign Sovereign Immunities Act’s (FSIA) arbitration exception applied because the award was governed by the New York Convention, an international arbitration treaty. Nigeria appealed, arguing that it was immune from suit under the FSIA.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the FSIA’s arbitration exception applied because the arbitration award arose from a legal relationship considered commercial, governed by the New York Convention. The court found that Nigeria had an arbitration agreement with Zhongshan, an arbitration award was issued, and the award was governed by the New York Convention. The court rejected Nigeria's argument that the New York Convention only applies to private acts, holding that the treaty covers arbitral awards arising from sovereign acts when a state consents to arbitration. Thus, the court affirmed the district court's jurisdiction and the enforceability of the arbitration award. View "Zhongshan Fucheng Industrial Investment Co. Ltd v. Federal Republic of Nigeria" on Justia Law

A member of the United Mine Workers of America arbitrated a dispute against Consol Energy, Inc. and won. The Union then sued to confirm the arbitration award, while Consol and its subsidiaries counterclaimed to vacate the award. The Union argued that the subsidiaries could not unilaterally reduce health benefits promised to miners for life, even if they no longer mined coal. Consol, which served as the health-plan administrator, had sent a letter indicating potential changes to benefits after the agreement expired, prompting the arbitration.The United States District Court for the District of Columbia dismissed the Union’s claim for lack of standing, reasoning that the Union was not injured as Consol had not actually modified the benefits. The court also declined to vacate the arbitration award on the merits of the Subsidiaries’ counterclaim. Both parties appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the Union’s claim did not fall under § 301(a) of the Labor Management Relations Act, which only authorizes suits for actual violations of contracts, not anticipated future violations. Consequently, the Union’s claim was dismissed for lack of subject-matter jurisdiction. Regarding the Subsidiaries’ counterclaim, the court determined that the Subsidiaries lacked standing as they were not named in the arbitration award and had not shown a concrete and imminent injury. The court vacated the district court’s orders on the Subsidiaries’ counterclaim and remanded it with instructions to dismiss for lack of standing.Thus, the appellate court affirmed the dismissal of the Union’s claim and vacated and remanded the Subsidiaries’ counterclaim for dismissal due to lack of standing. View "International Union, United Mine Workers of America v. Consol Energy Inc." on Justia Law

The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law

In 2017, Special Counsel Robert S. Mueller III began investigating Russian interference in the 2016 presidential election, during which Giorgi Rtskhiladze testified before a grand jury. When the Department of Justice (DOJ) released a redacted version of Mueller’s report, it included information that Rtskhiladze claimed was inaccurate and damaging to his reputation. Rtskhiladze sued for both equitable and monetary relief and sought a copy of his grand jury testimony transcript.The United States District Court for the District of Columbia ruled that Rtskhiladze lacked standing for his equitable claims, failed to state a claim for damages, and was not entitled to obtain a copy of the transcript. The court found that Rtskhiladze had abandoned his separate damages claim against DOJ and Mueller personally and forfeited arguments about this claim on appeal.The United States Court of Appeals for the District of Columbia Circuit held that Rtskhiladze has standing to bring all his claims and remanded the equitable claims for further consideration. The court agreed with the district court that Rtskhiladze failed to state a claim for damages under the Privacy Act, as he did not allege "intentional or willful" conduct by DOJ. The court also upheld the district court’s decision to deny Rtskhiladze’s request to obtain a copy of his grand jury testimony transcript, emphasizing the government’s interest in maintaining grand jury secrecy and preventing witness intimidation.In summary, the appellate court reversed the district court’s dismissal of Rtskhiladze’s equitable claims for lack of standing, affirmed the dismissal of his damages claim for failure to state a claim, and upheld the denial of his request to obtain a copy of his grand jury transcript. View "Rtskhiladze v. Mueller" on Justia Law

Ghulam Ali, an economist at the Environmental Protection Agency (EPA), suffers from severe allergies. For years, the EPA accommodated his condition by providing a suitable workspace. However, in 2011, the EPA placed a heavily perfumed colleague next to Ali, exacerbating his allergies. Ali requested a private office or a small conference room as an accommodation. Instead, the EPA offered him 100% telework, which Ali rejected, citing concerns about his home setup and the need for in-person collaboration. Ali then filed a lawsuit under the Rehabilitation Act, claiming the EPA failed to provide a reasonable accommodation.The United States District Court for the District of Columbia granted summary judgment in favor of the EPA. The court concluded that Ali caused a breakdown in the interactive process by rejecting the telework offer without providing sufficient explanation. The court held that Ali bore sole responsibility for the failure to settle on an appropriate accommodation.The United States Court of Appeals for the District of Columbia Circuit reversed the district court's decision. The appellate court found that Ali had provided all requested information and had proposed alternative accommodations, which the EPA either ignored or rejected. The court determined that whether the EPA's offer of 100% telework was a reasonable accommodation involved disputed material facts that should be resolved by a jury. The court emphasized that the reasonableness of an accommodation is often a fact-intensive question and that Ali's concerns about telework, including the need for in-person interaction and the unsuitability of his home for permanent work, were valid issues for a jury to consider. The case was remanded for further proceedings. View "Ali v. Regan" on Justia Law

Eva Mae Givens applied for Medicaid assistance in Washington, D.C., but the District miscalculated her copay, requiring her to pay an extra $2,000 per month. Givens requested an administrative hearing to contest the miscalculation, but D.C. did not provide a timely hearing as required by federal law. Givens then filed a lawsuit under 42 U.S.C. § 1983, seeking injunctive and declaratory relief for a fair hearing and monetary damages for the overpayments. While the case was pending, D.C. held a hearing, corrected the miscalculation, and sent back-payments to the nursing homes, but not to Givens. Givens passed away shortly after the hearing.The United States District Court for the District of Columbia dismissed the case with prejudice, ruling that the claims were moot because D.C. had provided the hearing and corrected the miscalculation. The court also held that Givens failed to state a claim for relief. Givens' children, who sought to be substituted as plaintiffs, appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the dismissal of the fair-hearing claims as moot but noted that the dismissal should have been without prejudice. The court found that the calculation claim was not moot because Givens had not received compensation for the overpayments she made. However, the court held that the calculation claim failed to plausibly allege a violation of federal rights under § 1983, as Givens did not identify a specific municipal policy or custom that caused the miscalculation.The appellate court vacated the district court's order dismissing the case with prejudice and remanded the case. The district court was instructed to dismiss the moot fair-hearing claims without prejudice and to either dismiss the calculation claim without prejudice or provide a detailed explanation for a dismissal with prejudice. View "Givens v. Bowser" on Justia Law

Agudas Chasidei Chabad of United States (Chabad) sought to reclaim religious property expropriated by the Russian Federation. Chabad obtained a default judgment against the Russian Federation and its agencies, which ignored the order to return the property. Consequently, the district court imposed monetary sanctions, accruing to over $175 million. Chabad attempted to collect these sanctions by attaching the property of three companies it claimed were controlled by the Russian Federation.The United States District Court for the District of Columbia initially granted Chabad’s motion to dismiss the Russian Federation’s claim of immunity under the Foreign Sovereign Immunities Act (FSIA). The court held that it had jurisdiction under the FSIA’s expropriation exception. However, the court later denied Chabad’s motion to attach the property of Tenex-USA, Tenex JSC, and VEB without prejudice, citing a lack of proper notice of the sanctions judgments to the Russian Federation.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the district court lacked jurisdiction over Chabad’s claims against the Russian Federation under the FSIA’s expropriation exception. The court determined that the expropriated property was not present in the United States, a requirement for jurisdiction under the FSIA. Consequently, the default judgment and sanctions judgments against the Russian Federation were void. The court vacated the district court’s decision and remanded for further proceedings consistent with its opinion, effectively dismissing the Russian Federation from the case. View "Agudas Chasidei Chabad of United States v. Russian Federation" on Justia Law