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

After plaintiffs prevailed in a long-running Individuals with Disabilities Education Act class action, the district court relied on the USAO's new matrix in awarding attorney fees. The DC Circuit vacated the award and held that the new matrix departs from the statutory requirement in 20 U.S.C. 1415(i)(3)(C) that reasonable fees be tethered to "rates prevailing in the community" for the "kind and quality of services furnished." Accordingly, the court remanded for the district court to recalculate the hourly rate based on evidence that focuses on fees for attorneys practicing complex federal litigation in the District of Columbia. View "DL v. District of Columbia" on Justia Law

After plaintiff was eliminated as part of a reorganization from his job of nearly 30 years, he filed suit against DC Water, alleging claims under various federal and D.C. civil rights statutes. The DC Circuit affirmed the district court's grant of summary judgment in favor of DC Water, holding that petitioner's Americans with Disabilities Act and DC Human Rights Act claims were time-barred; plaintiff failed to exhaust his administrative remedies prior to bringing his Title VII and Age Discrimination in Employment Act claims; it was within the district court's discretion to conclude that further discovery on plaintiff's only potentially viable claim—the one brought under 42 U.S.C. 1981—was unwarranted, given the lack of detail in plaintiff's Federal Rule of Civil Procedure 56(d) declaration; and summary judgment on plaintiff's section 1981 claim was appropriate given the record before the district court. View "Haynes v. District of Columbia Water and Sewer Authority" on Justia Law

After Esther Klieman was killed in a terrorist attack on an Israeli public bus, plaintiffs filed suit under the Anti-Terrorism Act (ATA), among other laws. The district court dismissed the case against the Palestinian Authority (PA) and the Palestinian Liberation Organization (PLO) for want of personal jurisdiction.The DC Circuit held that the district court did not abuse its discretion in agreeing, in light of the intervening Supreme Court case of Daimler AG v. Bauman, 571 U.S. 117 (2014), to reconsider its earlier ruling that the district court had general personal jurisdiction over defendants. The court held that Daimler, and circuit precedent, effectively foreclosed a ruling that the district court had general jurisdiction over the PA/PLO; plaintiffs' prima facie case for specific jurisdiction did not meet the Constitution's requirements; and plaintiffs have neither established the circumstances rendering section 4 of the Anti-Terrorism Clarification Act of 2018 applicable nor facts justifying a remand for discovery on the issue. Accordingly, the court affirmed the district court's decision. View "Estate of Esther Klieman v. Palestinian Authority" on Justia Law

As a result of newly discovered evidence of a Brady violation, the district court vacated defendant's narcoterrorism conviction and resentenced him to concurrent terms of 300 months on the two remaining convictions for conspiracy to distribute heroine and distributing heroin. The DC Circuit held that the district court did not abuse its discretion by denying defendant's motion for a continuance where the denial did not present a legal bar to prevent him from accessing jury selection records.However, the court agreed with defendant that there was insufficient evidence to support a two-point sentencing enhancement for possession of a firearm during a drug offense. Finally, defendant acknowledged that he could not prevail on his contention that the sentence was unconstitutional because the district court considered uncharged and acquitted conduct in calculating the base offense level. Accordingly, the court remanded for resentencing, but otherwise affirmed the judgment. View "United States v. Bagcho" on Justia Law

At the second prong of the McDonnell Douglas framework, an employer must proffer admissible evidence showing a legitimate, nondiscriminatory, clear, and reasonably specific explanation for its actions. Plaintiff filed suit alleging that one aspect of the Department's promotion process had a disparate impact on Hispanic and Latino candidates who applied for the position he sought, and that the Secretary in 2008 denied him a promotion because of his Hispanic ethnicity. The district court granted summary judgment in favor of the Secretary.The DC Circuit affirmed in part and held that plaintiff's disparate impact claim lacked merit where there were no genuine issues of material fact and plaintiff failed to establish causation as a matter of law. However, the court held that the district court misapplied the second step of the McDonnell Douglas framework as to the disparate treatment claim by accepting the Department's vague reason for the denial of the promotion. In this case, none of the presented evidence sheds light on how the selection boards applied the core precepts to defendant's case. Accordingly, the court reversed in part, vacated the denial of plaintiff's cross-motion in part, and remanded for further proceedings. View "Figueroa v. Pompeo" on Justia Law

In this consolidated opinion, the DC Circuit addressed cases arising from the Beirut, Nairobi, and Dar es Salaam terrorist attacks. On appeal, plaintiffs challenged the district court's dismissals of their claims against Iran, contending that the district courts erred in raising the statute of limitations sua sponte and in dismissing their complaints as untimely. One group of plaintiffs challenged the denial of motions for relief from judgment that they filed after their claims were dismissed.The DC Circuit did not reach the statute of limitations issue or the postjudgment motions. Rather, the court held that the district court lacks authority to sua sponte raise a forfeited statute of limitations defense in a Foreign Sovereign Immunities Act (FSIA) terrorism exception case, at least where the defendant sovereign fails to appear. Accordingly, the court reversed the district courts' judgments, vacated the dismissals of the complaint, and remanded for further proceedings. View "Maalouf v. Islamic Republic of Iran" on Justia Law

The DC Circuit affirmed defendant's conviction for three counts of bank robbery, holding that the district court did not abuse its discretion by declining to appoint substitute counsel for defendant, nor was it an error of law to conclude that defendant could voluntarily choose to proceed pro se. Furthermore, the district court's Faretta colloquy was not otherwise defective where the district court confirmed that defendant knew he was entitled to counsel regardless of his financial status and that he understood the nature of the charges against him and the maximum penalties he faced. View "United States v. Wright" on Justia Law

Coal miners filed suit alleging that mine operators interfered with their rights under Section 103(g) of the Federal Mine Safety and Health Amendments Act of 1977 to raise anonymous complaints with the MSHA regarding health and safety issues. The Commission imposed various remedies, including a $20,000 penalty per violation and an order requiring Robert Murray, the President and CEO of Murray Energy, to personally hold a meeting at each mine and read a statement regarding the violations.The DC Circuit denied a petition for review and declined to decide whether the Commission applied the correct test of interference under Section 105(c)(1) because petitioners failed to raise and preserve the issue during the administrative proceedings before the ALJ and the Commission. The court also found that, even under the legal standard that petitioners would have the court adopt, substantial evidence in the record clearly supports the Commission's finding that petitioners interfered with miners' Section 103(g) rights. Furthermore, the court found no merit in petitioners' challenge to the assessment of monetary penalties. Finally, the court held that petitioners failed to properly raise and preserve, and thus forfeited, their claims challenging the order requiring Murray to read a statement. View "Marshall County Coal Co. v. Federal Mine Safety and Health Review Commission" on Justia Law

The State of Missouri filed suit alleging that the Bureau of Reclamation violated the National Environmental Policy Act (NEPA) by failing to consider adequately how diverting billions of gallons of Missouri River water pursuant to the Northwest Area Water Supply Project will affect downstream States. The DC Circuit affirmed the district court's dismissal of the complaint and held that, under Massachusetts v. Mellon, 262 U.S. 447, 485–86 (1923), a state does not have standing as parens patriae to bring an action against the federal government. In this case, Missouri lacked Article III standing because it forfeited its direct injury theory of standing, and the Mellon bar has no exception that allows lawsuits against Reclamation to proceed. View "Government of the Province of Manitoba v. Bernhardt" on Justia Law

An investment adviser and its principals petitioned for review of the SEC's determination that they violated Section 206(2) and Section 207 of the Investment Advisers Act. The SEC alleged that petitioners failed for many years to disclose its arrangement with Fidelity and the conflicts of interest arising from that compensation.The DC Circuit denied the petition in part, holding that the Commission's findings of negligent violations under section 206(2) were supported by substantial evidence. However, the court granted the petition in part, holding that the Commission's findings of willful violations under section 207 based on the same negligent conduct were erroneous as a matter of law where the repeated failures to adequately disclose conflicts of interest were no more than negligent. View "The Robare Group, Ltd. v. SEC" on Justia Law