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

This suit involved a challenge to the "minimum essential coverage provision," which required all "applicable individual[s]" to purchase and maintain "minimum essential coverage" for each month beginning in January 2014 under the Patient Protection and Affordable Care Act (Act), Pub. L. No. 111-148, 124 Stat. 119. Appellants, four United States citizens and federal taxpayers, sought declaratory and injunctive relief to prevent various U.S. Government officials and agencies from enforcing the minimum essential coverage provisions. They argued that the mandate exceeded Congress's authority under the Commerce Clause and substantially burdened appellants' religious exercise, in violation of the Religious Freedom Restoration Act, 42 U.S.C. 2000bb et seq. The district court rejected appellants' challenge to the Act and they appealed. Despite questions raised as to the court's subject matter jurisdiction, the court concluded that it had jurisdiction and affirmed the district court's conclusion that the Act was constitutional. View "Seven-Sky v. Holder, Jr." on Justia Law

This case stemmed from the mortgage plaintiff carried on her New York house. In 2001, WaMu acquired the note and mortgage and then assigned it to Fannie Mae. Thereafter, plaintiff's home went into foreclosure, WaMu failed, and the FDIC became its receiver. In 2009, plaintiff brought this action against the FDIC, alleging that WaMu "owned and/or serviced the mortgage," and that it engaged in wrongful conduct in the foreclosure's aftermath. The district court sua sponte dismissed the complaint under Rule 12(b)(1) on the ground that plaintiff lacked standing. Plaintiff appealed and the FDIC argued that the court lacked jurisdiction to hear the appeal because plaintiff's notice of appeal was untimely. The court held that the district court's order ran afoul of Rule 4(a)(5)(C), which limited any extensions to thirty days, meaning that the last permissible day would have been the day before plaintiff filed her notice. The court agreed with plaintiff that the Rule 4(a)(5)(C) time limit was a claim-processing rule, not a jurisdictional bar, and that the FDIC forfeited its timeliness objection. The court reversed the decision of the district court and remanded for further proceedings. View "Youkelsone v. FDIC" on Justia Law

In this case, defendant invoked the Sentencing Commission's reductions in the offense level for certain crack cocaine offenses. The district court denied defendant's motion, noting on the record a host of facts about defendant's criminal record and his disciplinary infractions in prison. Defendant appealed, arguing that the district court failed to determine the extent of the reduction for which he was eligible before denying his motion. In particular, defendant believed that the court could have underestimated the permissible reduction in the sentencing range, and that this hypothetical underestimate could have played a role in the court's refusal to make any reduction at all. Although the court agreed with defendant that a motion under 18 U.S.C. 3582(c)(2) required the court first to compute the sentence reduction available, the court found that the record established that it did so. View "United States v. David" on Justia Law

Relator, on behalf of the United States, appealed the district court's dismissal of his qui tam complaint for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1). The district court held that an earlier-filed complaint barred its consideration of relator's complaint under the first-to-file rule of the federal False Claims Act (FCA), 31 U.S.C. 3730(b)(5). At issue was whether Section 3730(b)(5) required the first-filed complaint to meet the heightened pleading standards of Federal Rule of Civil Procedure 9(b) for alleging fraud in order to bar a later-filed complaint. The court held that the earlier-filed complaint alleged the same material elements of a fraudulent scheme as relator's complaint, and that the earlier-filed complaint need not meet the heightened pleading standards of Rule 9(b) to allege facts sufficient to prompt a government investigation, and thus, to bar later-filed complaints under Section 3730(b)(5). The court also held that relator waived his argument that the case should not have been dismissed with prejudice. View "Batiste v. SLM Corp." on Justia Law

Petitioner sought review of a decision of the Federal Mine Safety and Health Review Commission, an agency within the United States Department of Labor. The issue on appeal was whether a Mine Safety and Health Administration (MSHA) inspector was authorized to designate the violation of a safeguard notice issued pursuant to section 314(b) of the Federal Mine Safety and Health Act of 1977 (Mine Act), 30 U.S.C. 801 et seq., as "significant and substantial" under section 104(d)(1) of the Mine Act, which limited the "significant and substantial" designation to a violation of a "mandatory health or safety standard." The court agreed with the Commission majority that the violation of a safeguard notice issued pursuant to section 314(b) amounted to a violation of section 314(b) and was therefore a violation of a mandatory safety standard which could be designated "significant and substantial." Accordingly, the court denied the petition. View "Wolf Run Mining Co. v. MSHR" on Justia Law

Feld Entertainment, Inc. owned the country's largest collection of endangered Asian elephants, some of whom travel and perform with its famed Ringling Brothers and Barnum & Bailey Circus. In this case, a former barn helper with the circus and an organization dedicated to fighting exploitation of animals alleged that Feld's use of two techniques for controlling the elephants -bullhooks and chains - harmed the animals in violation of the Endangered Species Act, 16 U.S.C. 1533(a)(1). The court agreed with the district court that plaintiffs failed to establish Article III standing and therefore affirmed the district court's judgment. View "ASPCA, et al. v. Feld Entertainment, Inc." on Justia Law

Three environmental organizations petitioned for review of the EPA's promulgation of a final rule where the "conformity determinations" referred to in the rule's title were approvals needed under the Clean Air Act (CAA), 42 U.S.C. 7506(c)(1), for federally funded transportation projects in an area that was designated "nonattainment" or "maintenance" with respect to the National Ambient Air Quality Standards. Petitioners principally argued that the 2010 Rule still failed to embody subsection (B)(iii)'s requirements that the project not "delay timely attainment on any standard or any required interim emission reduction or milestones in any area." The court held that, given the EPA's clarification that (B)(iii) applied to local projects and its persuasive explanation of how the substance of the "delay" condition was met, the court was satisfied that the 2010 Rule was not arbitrary, capricious, or inconsistent with law for the reasons raised in Environmental Defense, Inc. v. EPA. In particular, it was clear that a project giving rise to the "counterbalance" hypothetical the court described in Environmental Defense would not be deemed conforming. Accordingly, the petition was denied. View "NRDC, et al. v. EPA" on Justia Law

As part of a civil enforcement action brought by the SEC, the district court entered a disgorgement order against Peter S. Cahill, imposing joint and several liability for the full proceeds of his sales of stock in a small, thinly traded corporation not listed on a major stock exchange. Cahill challenged the order. The court held that because Cahill presented no evidence in rebuttal, the district court did not clearly err in finding that the SEC had met its burden to show that his ill-gotten gains were the full proceeds of his stock sales at inflated prices resulting from a fraudulent "pump and dump" scheme. Neither did the district court abuse its discretion in crafting the disgorgement remedy. Inclusion of the transferred funds was consistent with the court's precedent. Absent any rationale for a different approach, the court joined other circuits in holding that the imposition of joint and several liability for the amount ordered to be disgorged did not require proof of a close relationship among the defendants beyond their collaboration in the fraudulent scheme in violation of the securities laws. Accordingly, because Cahill's evidentiary objections were also unavailing, the court affirmed the order of disgorgement. View "Securities and Exchange Comm'n v. Whittemore, et al." on Justia Law

Petitioners challenged the FAA's issuance of 130 Determinations of No Hazard for each of the proposed wind turbines in the area of Nantucket Sound. Petitioners argued that the FAA violated its governing statute, misread its own regulations, and arbitrarily and capriciously failed to calculate the dangers posed to local aviation. The FAA claimed that petitioners lacked standing to challenge the FAA's determinations and that their merits claims were faulty. The court found that petitioners had standing and that the FAA misread its regulations, leaving the challenged determinations inadequately justified. Accordingly, the petitions for review were granted and the FAA's determinations were vacated and remanded. View "Town of Barnstable, MA v. Federal Aviation Admin." on Justia Law

Appellant appealed his conviction and sentence on two counts of attempted tax evasion. Appellant argued that the government failed to prove the element of tax loss because it relied upon a flawed calculation under the "cash method of proof" and attributed to appellant $1.9 million of alleged gain when those funds, as a matter of law, belonged to his two corporations. Appellant challenged his sentence to the extent it rested upon the allegedly incorrect calculation of tax loss. The court found no error in the district court's denial of defendant's motions for judgment of acquittal. The court also held that, because a rational trier of fact could find beyond a reasonable doubt a tax was due and owing on $300,000 of income, the court left for another day how best to interpret the dictum in James v. United States. The court affirmed the sentence because the district court made sufficient factual findings at sentencing to support the inclusion of the $1.9 million in the calculation of tax loss. View "United States v. Khanu" on Justia Law