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

Plaintiff filed suit against defendants, seeking compensatory and punitive damages after a thirteen-year delay in receiving a jury award against the RNC. The DC Circuit reversed the district court's sua sponte dismissal of the complaint for want of federal jurisdiction under the Rooker-Feldman doctrine. The court held that, to the extent the complaint called for appeal of a District of Columbia court order issued in plaintiff's suit against the RNC, any such claim was barred by Rooker-Feldman. However, Rooker-Feldman did not bar those portions of the complaint against the Joint Committee that did not seek to appeal orders in his Superior Court suit against the RNC. In this case, neither plaintiff's claim that Superior Court administrative personnel violated his property rights by misleading him and mishandling his award, nor his claim that court administrators neglected their legal duty to make the courts accessible to persons with disabilities like his, necessarily called for the federal courts to review any state court judgment. Accordingly, the court remanded for further proceedings. View "Croley v. Joint Committee on Judicial Administration" on Justia Law

EIG, an American investment fund, filed suit against Petrobras and others, alleging counts of fraud, aiding and abetting fraud and civil conspiracy to commit fraud. EIG's claims stemmed from its loss of a $221 million investment in an undersea oil-drilling project off the coast of Brazil. Petrobras moved for dismissal based on lack of subject matter jurisdiction, arguing that Petrobras was an instrumentality of the Brazilian state and thus immune from suit under the Foreign Sovereign Immunities Act. The DC Circuit affirmed the district court's order denying dismissal, holding that Petrobras was not immune from EIG's suit. The court concluded that Petrobras's commercial activity in Brazil caused a direct effect in the United States, including a direct effect on EIG. View "EIG Energy Fund XIV, L.P. v. Petroleo Brasileiro, S.A." on Justia Law

Plaintiffs sought a declaratory judgment that they were not subject to federal recordkeeping laws dealing with the distribution of cigarettes. The DC Circuit held that neither the Contraband Cigarette Trafficking Act of 1978 nor the implementing regulations contain any language exempting tribal entities operating on Indian reservations from the federal recordkeeping requirements. The Act's recordkeeping requirements apply to any person; under federal law, "person" includes "corporations"; plaintiffs are "corporations"; and therefore plaintiffs are "persons" and the Act's recordkeeping requirement applied to them. Furthermore, the statutory context was another reason why the district court correctly held that Congress did not exempt the corporate plaintiffs from the Act's recordkeeping provision. View "Ho-Chunk, Inc. v. Sessions" on Justia Law

The DC Circuit affirmed the district court's enforcement of the arbitration panel's award against Argentina. The panel held that Argentina was liable to AWG for breach of a contract for the country's water services. Argentina argued that a member of the arbitration panel had, with a connection to two of the parties to the proceeding, shown "evident partiality" under 9 U.S.C. 10(a)(2), and that the way the panel reached its determination exceeded its authority under section 10(a)(4). The court held that the interests at issue were trivial and could not have created evident partiality. Therefore, the court found no basis to vacate the panel's award under section 10(a)(2) of the Federal Arbitration Act. The court also held that Argentina failed to show that the panel's decision had no basis in the governing arbitration agreement. Likewise, the court could not vacate the award under the New York Convention. View "Republic of Argentina v. AWG Group Ltd." on Justia Law

The DC Circuit affirmed defendant's conviction under District of Columbia law of sexually abusing a minor, and under federal law of producing, possessing, and distributing child pornography. The court held that the jury heard sufficient evidence from which to infer that defendant induced the minor's lascivious exhibition of his genitals in order to photograph it. In regard to the form of the government's questions, the court held that the district court had discretion to let the government ask, a very reticent witness, to clarify the nature of his sexual contact with defendant in the manner that it did. View "United States v. Torres" on Justia Law

Defendant challenged the denial of a collateral attack pursuant to 28 U.S.C. 2255 on a conviction by a jury of crimes relating to a series of armed bank robberies. The DC Circuit held that defendant's contention that his trial and appellate counsel failed to object to the closure of voir dire, in violation of his Sixth Amendment right to a public trial was foreclosed in light of Weaver v. Massachusetts, 137 S. Ct. 1899 (2017), because he has not shown prejudicial error from the voir dire closure. The court held that defendant's second contention regarding the plea offer required remand because the motion and the files and records of the case did not conclusively show that he was entitled to no relief. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "United States v. Aguiar" on Justia Law

The DC Circuit affirmed defendant's conviction for conspiracy to distribute and possess with the intent to distribute five kilograms or more of cocaine. The court held that the presumption against extraterritoriality applied in this case and the evidence showed that the relevant conduct occurred in the United States; the court rejected defendant's "manufactured venue" claim and the district court did not err in determining that venue was not a question for the jury to decide; and the court rejected defendant's contention that venue was not proper in D.C. The court held that defendant was not denied due process of law and he failed to establish a violation under Brady v. Maryland. Finally, the court rejected defendant's claim that the government knowingly presented false evidence at trial in violation of Napue v. Illinois. The court rejected defendant's remaining claims. View "United States v. Sitzmann" on Justia Law

At issue was whether plaintiff's employment discrimination claims under Title VII, 42 U.S.C. 2000e et seq., were subject to ordinary principles of res judicata, even though at the time she filed her earlier suit she had not yet received a notice of her right to sue for those claims. The DC Circuit joined its sister circuits and held that res judicata applies to such Title VII claims, at least in the absence of a particularized showing that prosecuting or otherwise preserving the claims in the initial litigation was infeasible. In this case, including plaintiff's Title VII claims in her initial litigation was entirely feasible. Therefore, the court affirmed the district court's dismissal of the complaint. View "Ashbourne v. Hansberry" on Justia Law

The DC Circuit affirmed the district court's refusal to set aside a jury verdict in favor of plaintiff on one of her due process claims. Plaintiff filed suit against the District after she was terminated based on accusations that she had improperly influenced the bidding process for the District's healthcare contracts. Plaintiff alleged that the District violated her Fifth Amendment due-process rights by leaking these accusations to the press and denying her an opportunity to refute them. The court held that the District failed to preserve its speech argument and such failure precluded appellate review where the District failed to identify any exceptional circumstances. The court also held that precedent did not mandate a rigid minimum-duration rule governing how long a former government employee must be unemployed before she can claim that the government's actions had the broad effect of largely precluding her from pursuing her chosen career. Therefore, the court rejected the District's argument that two years of unemployment is never sufficient to establish that plaintiff has been deprived of her liberty interest. Accordingly, the court affirmed the denial of the District's motion for judgment as a matter of law. View "Campbell v. District of Columbia" on Justia Law

The DC Circuit held that 42 C.F.R. 405.1885 does not apply to appeals from a fiscal intermediary to the Provider Reimbursement Review Board. Therefore, the court had no occasion to address whether the 2013 amendments to the reopening regulation were arbitrary and capricious or whether applying the amendments to proceedings pending on their effective date would be impermissibly retroactive. Accordingly, the court reversed and remanded for further proceedings. View "Saint Francis Medical Center v. Azar" on Justia Law