Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Articles Posted in Government & Administrative Law
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Plaintiffs, health care providers and their patients, filed suit against Iowa's Department of Public Health and its Health Facilities Council, alleging that Iowa's Certificate of Need laws violate the Fourteenth Amendment's Due Process, Equal Protection, and Privileges and Immunities Clauses. The Eighth Circuit held that plaintiffs' Privileges and Immunities Clause claim was foreclosed by the Slaughter-Houses cases. Applying rational basis review to the Certificate of Need (CON) regime and capital expenditures exemption, the court held that Iowa's CON requirement is rationally related to a legitimate state interest in full-service hospital viability. Furthermore, Iowa's decision to exempt competitors who are non-hospital CON-holders is rationally related to its interest in protecting the viability of full-service hospitals. Therefore, the court affirmed the district court's orders dismissing plaintiffs' Privileges and Immunities claim and granting summary judgment in favor of the state defendants on the remaining claims. View "Birchansky v. Clabaugh" on Justia Law

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The Eighth Circuit granted a petition for review of the ARB's final decision ruling that CP violated the whistleblower retaliation provisions of the Federal Railroad Safety Act (FRSA) when it suspended a locomotive engineer for his untimely reporting of a "work-related personal injury" or a "hazardous safety or security condition." The court agreed with CP's argument that the ARB's analysis of the contributing factor element of the employee's prima facie case used a legal causation standard contrary to controlling Eighth Circuit precedents. The court held that the ARB's reasoning was both contrary to the court's governing precedents and fatally flawed; the FRSA prohibits a rail carrier from discriminating against an employee for engaging in protected activity; the employee does not have to conclusively prove retaliatory motive but must show more than temporal proximity between the protected activity and the adverse action; and the court expressly rejected the contention that, when an employer learns about an employee's conduct warranting discipline in a protected injury report, the report and the discipline are "inextricably intertwined" and this factual connection is "sufficient to establish the contributing-factor element of his prima facie case." Because the ARB did not attempt to apply the appropriate Eighth Circuit legal standard, the court remanded to the ARB with instructions. View "Dakota, Minnesota & Eastern Railroad Corp. v. U.S. Department of Labor Administrative Review Board" on Justia Law

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MHA filed suit challenging the part of DSH's 2017 Rule defining "costs incurred" as "costs net of third-party payments, including, but not limited to, payments by Medicare and private insurance." The Eighth Circuit reversed the district court's grant of summary judgment for MHA, holding that the statute did not delegate to the Secretary unfettered discretion to determine "costs incurred;" the terms "costs incurred" and "net of payments" have plain, unambiguous meanings; and MHA's interpretation of "costs" and "payments" was not plainly mandated by the structure of the statute. Therefore, the court held that the Secretary's interpretation was reasonable in light of the statute's purpose and design. Under Missouri's plan, the court explained that the State redistributes overpayments above a particular hospital's DSH annual limit proportionately among other DSH hospitals that are below their hospital-specific limits, redistributions that should benefit the most imperiled DSH members of the MHA. View "Missouri Hospital Assoc. v. Azar" on Justia Law

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Kearney sought judicial review of the Board's decision denying its application to participate in the Medicare program. Although the facility later received approval, the initial denial prevented Kearney from participating in Medicare and receiving reimbursements for 87 days during 2014. The Eighth Circuit held that the Board failed adequately to explain the legal standard that it applied in resolving Kearney's administrative appeal. In this case, the court was unable to discern what meaning the Board attributed to 42 U.S.C. 1395x(e)(1) and the definition of "hospital." Furthermore, without an adequate explanation for what time period the agency considered in determining whether Kearney was primarily engaged in providing care to inpatients, the court was unable to resolve whether the Board's decision correctly applied the relevant legal standards. Therefore, the court reversed the district court's grant of summary judgment to the Department and remanded with directions. View "Kearney Regional Medical Center, LLC v. US Department of Health and Human Services" on Justia Law

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Suits over oil and gas leases on allotted trust lands are governed by federal law, not tribal law, and the tribal court lacks jurisdiction over the nonmember oil and gas companies. This appeal involved a dispute over the practice of flaring natural gas from oil wells, and at issue was the scope of Native American tribal court authority over nonmembers. The Eighth Circuit affirmed the district court's grant of a preliminary injunction enjoining the tribal court plaintiffs and tribal court judicial officials and held that the district court correctly rejected the tribal court officials' argument that this suit was barred by tribal sovereign immunity. The court also held that the district court did not abuse its discretion in granting the preliminary injunction because the oil and gas companies are likely to prevail on the merits. In this case, the district court correctly concluded that the oil and gas companies exhausted their tribal court remedies by moving to dismiss the case for lack of jurisdiction and appealing the issue to the MHA Nation Supreme Court; the district court correctly concluded that the tribal court lacked jurisdiction over the oil and gas companies; and the balance of the remaining preliminary injunction factors, along with the oil and gas companies' strong likelihood of success on the merits, showed that the district court did not abuse its discretion by granting the preliminary injunction. View "Kodiak Oil & Gas (USA) Inc. v. Burr" on Justia Law

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Plaintiff, along with her late husband, filed suit challenging a city ordinance that requires at least fifty percent of their residential yard to contain turf grass. The Eighth Circuit affirmed plaintiff's substantive due process claim, but held that the district court was without jurisdiction to dismiss the Eighth Amendment claim on the merits. In this case, plaintiff's claim that the city's ordinance violated her due process rights was barred by the doctrine of res judicata. Furthermore, the Eighth Amendment claim was not ripe for review, because it is unknown whether the city will impose sanctions or, if sanctions are imposed, what they might be. View "Duffner v. City of St. Peters" on Justia Law

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The Eighth Circuit reversed the district court's order granting summary judgment to the Metropolitan Council on LPA's claim that the Council violated the National Environmental Policy Act (NEPA) and other federal and state laws. In this case the Council is the sole defendant and LPA filed suit prior to a final agency action. The court held that the district court lacked jurisdiction to hear LPA's claim, because Eighth Circuit precedent expressly rejects the viability of a NEPA cause of action outside of the Administrative Procedure Act framework, especially when the only defendant is a state agency. Therefore, LPA has no cause of action through which it could state a plausible claim. The court remanded with instructions to dismiss the case. View "Lakes and Parks Alliance of Minneapolis v. The Metropolitan Council" on Justia Law

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The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims challenging the city's ordinance based on lack of standing. The challenged ordinance made it unlawful for any person to own, possess, keep, exercise control over, maintain, harbor, transport or sell within the City of Sioux City, Iowa, any pit bull. In this case, plaintiff admitted that she does not currently own a dog because she and her fiance work full time and do not have the time to own a dog, but she intended to adopt a dog in the near future. The court held that, to the extent plaintiff sought prospective relief against future conduct, she failed to show that she owns a dog and does not live in the city. Furthermore, her intention to adopt a dog in the near future was uncertain and insufficient to confer standing. The court also held that plaintiff's past injuries did not grant her standing because she failed to demonstrate how her proposed relief redressed them. Finally, the district court did not abuse its discretion by declining to hold an evidentiary hearing prior to its sua sponte dismissal of plaintiff's claim. View "Myers v. Sioux City" on Justia Law

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Hospitals challenged the method the Secretary used to calculate the volume-decrease adjustment (VDA) for certain fiscal years during the mid-2000s, as well as the Administrator's classification of certain costs as variable costs when calculating the adjustment. The Eighth Circuit affirmed the district court's decision to uphold the Secretary's actions and held that the Secretary's interpretation of the relevant regulations was a reasonable interpretation of the plain language of the Medicare statute. Given the lack of guidance in the statute and the substantial deference the court affords to the agency, the Secretary's decision reasonably complied with the mandate to provide full compensation. That the Secretary has prospectively adopted a new interpretation was not a sufficient reason to find the Secretary's prior interpretation arbitrary or capricious. The court also held that the Secretary's interpretation of the relevant regulations in these cases was clearly consistent with their text, and the costs at issue were reasonably classified as variable costs. View "Unity HealthCare v. Azar" on Justia Law

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The Eighth Circuit denied Petitioner’s petition for review of a decision of the Board of Immigration Appeals (BIA) affirming the immigration judge’s (IJ) denial of Petitioner’s motion to terminate removal proceedings, holding that substantial evidence supported the finding of the lower courts that Petitioner’s convictions qualified as crimes involving moral turpitude. Based on Petitioner’s Missouri convictions for receiving stolen property and passing bad checks, the Department of Homeland Security (DHS) charged Petitioner with removability. Petitioner filed a motion to terminate removal proceedings, alleging that DHS did not demonstrate that her convictions qualified as crimes involving moral turpitude. The IJ denied the petition, and the BIA affirmed. The Eighth Circuit affirmed, holding that, applying the modified categorical approach, Petitioner’s four Missouri convictions for passing a bad check qualified as crimes involving moral turpitude. View "Dolic v. Barr" on Justia Law