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

TRCP filed for declaratory and injunctive relief in the district court, arguing that the Bureau of Land Management's 2008 Record of Decision regarding the Pinedale Anticline Project Area (PAPA) violated the Federal Land Policy Management Act (FLPMA), 43 U.S.C. 1701 et seq.; that the accompanying environmental impact statement (EIS) violated the National Environmental Policy Act (NEPA), 42 U.S.C. 4321 et seq.; and the 2000 Record of Decision violated both acts. The district court granted summary judgment for the Bureau and TRCP appealed. The court held that the Bureau considered a reasonable range of alternatives in the EIS addressing the proposal to expand natural gas development in the PAPA. That EIS sufficiently addressed the proposed action's impact on hunting in the PAPA. The record supported the Bureau's determination that the 2008 Record of Decision would prevent unnecessary or undue degradation of the PAPA. Finally, TRCP's claims based on the Bureau's alleged non-enforcement of the 2000 Record of Decision were moot. Accordingly, the judgment of the district court was affirmed. View "Theodore Roosevelt Conservation P'ship v. Salazar" on Justia Law

Petitioner sought review of the NTSB's order affirming emergency revocation of his airman and medical certificates, which was based on the conclusion that he made an intentionally false statement on his medical certificate application when he failed to disclose an arrest for an alcohol-related motor vehicle accident. Petitioner contended that the Administrator of the Federal Aviation Administration (FAA) failed to prove intent because he had reported the arrest and suspension to the FAA almost two years earlier and hence lacked any motive to falsify his answer on the application. The NTSB ruled that petitioner's admitted failure to read the question before answering it constituted willful disregard for truth or falsity, and he thus had intentionally made a false statement in his application. The court held that because the willful disregard standard articulated in Administrator v. Boardman, and endorsed by the FAA was a reasonable interpretation of the regulation, the NTSB's deference to the FAA's interpretation of its regulation was not arbitrary or capricious, an abuse of discretion, or contrary to law. Accordingly, the court denied the petition for review. View "Cooper v. NTSB, et al." on Justia Law

Upon remand to the court after affirming one of his convictions, the district court granted a variance from the U.S. Sentencing Guidelines range for career offenders and re-sentenced defendant for unlawfully distributing more than 5 grams of cocaine base. The court held that, although defendant correctly pointed out that the amount of cocaine base of which he stood convicted was 21.1 grams, not the 29.6 grams of cocaine base stated in the Presentence Report and adopted by the district court in re-sentencing him, both amounts fell within the same quantity range under U.S.S.G. 2D1.1(c)(7) and carried a maximum sentence of 40 years. Thus, defendant's Guidelines offense level would have been 34 regardless. The court also held that defendant could not show error, much less plain error, where the district court refused to consider the effect of pending legislation. The court further held that the district court did not plainly err, in violation of defendant's Fifth Amendment right against self-incrimination, by referencing at re-sentencing his failure to express remorse and accept responsibility. The court finally held that defendant's challenge to the reasonableness of his below-Guidelines re-sentencing failed to demonstrate that the district court abused its discretion in applying the career offender guideline provision. Accordingly, the court affirmed the amended judgment. View "United States v. Lawrence" on Justia Law

The United States appealed the district court's grant of the writ of habeas corpus to the detainee. Three errors in the district court's analysis required the court to vacate that decision. First, the court failed to accord an official government record a presumption of regularity. Second, the district court failed to determine the detainee's credibility even though the court relied on his declaration to discredit the Government's key evidence. Third, the court's unduly atomized approach to the evidence was one the court rejected. The court remanded so the district court could evaluate the detainee's credibility as needed in light of the totality of the circumstances. View "Latif, et al. v. Obama, et al." on Justia Law

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