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

Kaboni Savage, a federal prisoner, brought a lawsuit against the U.S. Department of Justice arguing that the department was infringing upon his First Amendment rights by limiting his communication with family and friends. Savage claimed that the restrictions imposed under the Special Administrative Measures (SAMs) were unjust. However, Savage did not complete the Justice Department's Administrative Remedy Program (ARP), a process designed to seek relief from such restrictions. The United States District Court for the District of Columbia dismissed Savage's lawsuit, citing the Prison Litigation Reform Act of 1996 (PLRA), a law requiring prisoners to exhaust all available administrative remedies before bringing a lawsuit. The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's decision, stating that Savage did not fully pursue all available administrative remedies and hence, his lawsuit was barred under the PLRA. View "Savage v. DOJ" on Justia Law

In a case concerning allegations that New Republican PAC and Senator Rick Scott violated several election laws, the United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal of two administrative complaints made by End Citizens United PAC. The first complaint alleged that Scott became a "candidate" the same month he became chairman of New Republican, failed to register his campaign until nearly a year later, and failed to make the necessary filings and reports to the Federal Election Commission. The Commission dismissed this complaint based on prosecutorial discretion. The second complaint alleged unlawful coordination between Scott and New Republican, asserting that New Republican had improperly contributed to Scott's campaign by coordinating with Scott to purchase commercials. The Commission dismissed this complaint for lack of evidence supporting the coordination claim. The Court of Appeals held that the dismissal of the first complaint was unreviewable due to it being based on prosecutorial discretion, and that the dismissal of the second complaint was not contrary to law. View "End Citizens United PAC v. FEC" on Justia Law

In this case, the United States Court of Appeals for the District of Columbia Circuit was asked to review a decision from the National Labor Relations Board (NLRB). The NLRB had determined that T-Mobile had unlawfully dominated an organization it created known as T-Voice, which the NLRB classified as a "labor organization" under the National Labor Relations Act. The issue arose when T-Mobile, a national wireless telecommunications carrier, established T-Voice and selected employees to serve as representatives to raise issues with management. The Communications Workers of America filed an unfair labor practice charge against T-Mobile, alleging that T-Voice was a labor organization and that T-Mobile had unlawfully dominated it.In its decision, the Court of Appeals affirmed the NLRB's determination. The court held that the NLRB was correct in finding that T-Voice was a labor organization because the organization existed at least in part to deal with T-Mobile over working conditions, which is a key criterion for qualifying as a labor organization under federal law. The court further affirmed the NLRB's finding that T-Mobile had dominated T-Voice, which is prohibited by federal law. Consequently, the court denied T-Mobile's petition for review and granted the NLRB's cross-application for enforcement of its order. View "T-Mobile USA, Inc. v. National Labor Relations Board" on Justia Law

In the case between East Texas Electric Cooperative, Inc., and others, against the Federal Energy Regulatory Commission (FERC) and American Electric Power Service Corporation (AEP), the United States Court of Appeals for the District of Columbia Circuit reviewed FERC's decision regarding AEP's calculation of its 2019 transmission rates. The petitioners, customers of AEP, challenged the calculation, but FERC rejected their claims. The petitioners then sought a review of the agency's decision.The court stated that FERC had correctly interpreted AEP's tariff terms and did not act arbitrarily or capriciously. FERC's ruling was upheld on several points, including the denial of retroactive relief for alleged errors in previous rate years, the inclusion of certain coal-related costs in the 2019 rate, the classification of certain tax credits as prepayments for tax liabilities, and the classification of employee pension and benefit costs as non-contingent liabilities. Therefore, the court denied the petition for review. View "East Texas Electric Cooperative, Inc. v. Federal Energy Regulatory Commission" on Justia Law

The appellant, Hdeel Abdelhady, filed a suit against George Washington University ("the University") after being injured on the university's property. During the proceedings, the University submitted several exhibits that contained references to Abdelhady's private medical treatments and diagnoses. Abdelhady filed a motion to seal these exhibits to protect her medical privacy, but the District Court partially denied her motion. Abdelhady appealed this decision in the United States Court of Appeals for the District of Columbia Circuit.The appeals court first established its jurisdiction over the appeal by applying the "collateral order doctrine," which allows for immediate appeal of certain orders that are crucial and unreviewable after the final judgment. The court noted the high value of maintaining privacy in medical treatments and diagnoses and affirmed that an order denying a motion to seal records containing such information is immediately appealable.Turning to the merits of the appeal, the appeals court found that the District Court had erred in denying Abdelhady's motion to seal. It noted a lack of clarity in the District Court's decision and found that the lower court had relied on the incorrect assumption that Abdelhady had already disclosed in her redacted complaint all of the same information she sought to have sealed. The appeals court also found that the District Court did not adequately consider several factors that should guide such a decision, including the need for public access to the documents, Abdelhady's interest in medical privacy, and the extent of previous public access to the records.Consequently, the appeals court found that the District Court had abused its discretion and vacated the lower court's decision. The case was remanded back to the District Court for further consideration of all relevant factors and a more detailed explanation of its decision. The appeals court underscored that this remand did not imply that Abdelhady's motion to seal should have been granted in full, noting several ambiguities in her request. View "Abdelhady v. George Washington University" on Justia Law

In the case before the United States Court of Appeals for the District of Columbia Circuit, Russell Alford, who was a participant in the Capitol protest on January 6, 2021, appealed his convictions and sentence for four misdemeanors. The misdemeanors were related to his unauthorized entry and conduct within the U.S. Capitol. Although Alford's behavior while in the Capitol was neither violent nor destructive, he was convicted for his role in disrupting the Congress's electoral certification and endangering public safety.Alford raised two issues in his appeal: the sufficiency of the evidence to support his convictions for disorderly or disruptive conduct and the reasonableness of his twelve-month sentence. The court affirmed his convictions, noting that a jury could rationally conclude that his unauthorized presence as part of a mob contributed to the disruption of the Congress's proceedings. The court also affirmed his sentence, stating that the district court was within its discretion in imposing a within-Guidelines sentence after considering the circumstances.The case underscores that disorderly or disruptive conduct, as defined by relevant statutes, can include non-violent and non-destructive actions if they are likely to endanger public safety or create a public disturbance. Even passive conduct can be deemed disorderly or disruptive, depending on the context. The court also emphasized that sentencing disparities among defendants with similar records who have been found guilty of similar conduct are not inherently unreasonable, especially when the defendant's conduct during trial or other factors may justify a greater sentence. View "USA v. Alford" on Justia Law

The United States Court of Appeals for the District of Columbia Circuit reviewed the Federal Election Commission's (FEC) dismissal of an administrative complaint by the Campaign Legal Center (CLC). The CLC alleged campaign finance violations by two presidential campaign committees, claiming that they concealed over $750 million in expenditures by routing them through sham payments to two LLCs. The FEC dismissed the complaint, invoking prosecutorial discretion. The CLC argued that the FEC's invocation of discretion was dependent on legal analysis and was thus subject to judicial review under the Federal Election Campaign Act. The district court concluded that the FEC's reliance on considerations of prosecutorial discretion was separate from its legal analysis and precluded judicial review.On appeal, the Court of Appeals affirmed the district court's decision. The court held that the FEC's reasons for dismissal, which included resource allocation concerns, potential litigation risks, and a shifting regulatory landscape, were distinct considerations of prosecutorial discretion that did not solely rest on legal interpretation, and therefore were not reviewable by the court. The court rejected the CLC's argument that the FEC's invocation of discretion was intertwined with its legal analysis, stating that the agency's estimation of the resource demands of the proposed investigation and its potential size and scope bore no discernable relationship to any legal inquiry. View "Campaign Legal Center v. FEC" on Justia Law

The United States Court of Appeals for the District of Columbia Circuit examined a case involving the City of Lincoln, also known as Lincoln Electric, a public utility providing electricity to the Lincoln, Nebraska area. Lincoln Electric had invested in the Laramie River Station facilities (LRS) in eastern Wyoming as a source of generation and transmission, despite only serving customers in the Lincoln area.When Lincoln Electric joined the Southwest Power Pool (SPP) in 2009, it transferred control of all its facilities in the Lincoln area to SPP, but retained control of its LRS interest. In 2021, the SPP proposed that Lincoln Electric recover its LRS costs from Zone 19 customers, where LRS is physically located. Other co-owners of the LRS facilities recover their costs from Zone 19 customers.The Federal Energy Regulatory Commission (FERC) rejected the SPP proposal as unjust and unreasonable because Zone 19 customers neither caused Lincoln Electric's LRS investment nor benefited from it, thus violating the cost-causation principle. Lincoln Electric petitioned for review of the relevant FERC orders and the SPP intervened on Lincoln Electric's behalf.The court upheld FERC's decision, ruling that Lincoln Electric failed to demonstrate that the proposed rates were just and reasonable. The court concluded that cost allocation must reflect the costs actually caused by the customer who must pay them. In this case, Lincoln Electric's investment in the LRS was for the benefit of its own Zone 16 customers, not Zone 19 customers. As such, the court found that allocating Lincoln Electric's LRS costs to Zone 19 would violate the cost-causation principle. The petition for review was denied. View "City of Lincoln v. FERC" on Justia Law

In this case, the United States Court of Appeals for the District of Columbia Circuit is faced with deciding if a passenger on a train station platform, who involuntarily falls into a non-public area (a trough housing electrical and lighting equipment) and sustains severe injuries, becomes a trespasser due to his fall. The injured party, Okiemute C. Whiteru, was intoxicated and fell into the trough after attempting to sit on the station platform ledge. The fall resulted in a fractured vertebra, which led to his eventual death by asphyxiation. Whiteru's parents and estate filed claims of negligence and wrongful death against the Washington Metropolitan Area Transit Authority (WMATA), arguing that WMATA failed in its duty as a common carrier to render aid to Whiteru.In a previous decision, the court held that Whiteru's contributory negligence did not preclude liability for WMATA's failure to aid. However, on remand, WMATA argued that Whiteru's status changed from passenger to trespasser when he fell into the non-public area, thus reducing WMATA's duty of care. The district court granted WMATA's motion for summary judgment, accepting the argument that Whiteru became a trespasser upon his fall.The Appeals Court, however, found uncertainty in how to determine Whiteru's status under District of Columbia law as either a passenger or a trespasser, which in turn would determine WMATA's duty of care. The court found no controlling precedent from the District of Columbia Court of Appeals on this matter and thus certified the question to that court. The certified question asks if, under District of Columbia law, a passenger of a common carrier who involuntarily falls into a non-public area, sustaining immobilizing injuries, may recover for the exacerbation of the injuries due to the common carrier's failure to aid him, if the common carrier knew or had reason to know of the injuries. View "Whiteru v. WMATA" on Justia Law

In this case, the United States Court of Appeals for the District of Columbia Circuit considered an appeal by Khan Mohammed, who had been convicted of international drug trafficking and narcoterrorism and sentenced to two concurrent life sentences. The district court later vacated the narcoterrorism charge, and upon resentencing for the drug trafficking charge, applied a terrorism enhancement under Section 3A1.4 of the Sentencing Guidelines, again resulting in a life sentence.Mohammed appealed this new sentence, arguing that the district court committed legal and factual errors in applying the terrorism enhancement, and used the wrong burden of proof. The appellate court affirmed Mohammed’s sentence. The court found no plain error in the lower court's application of Section 3A1.4, rejecting Mohammed's argument that the language of the statute had been abrogated and that the enhancement should only apply to convictions of federal crimes of terrorism. The court also held that the district court did not err by applying a preponderance of the evidence standard to conduct that was the subject of Mohammed's vacated conviction, even if the case involved extraordinary circumstances. Lastly, the court upheld the district court's factual findings that supported the application of the terrorism enhancement, declining to disturb findings that had already been upheld on appeal. View "USA v. Mohammed" on Justia Law