Stanley Sporkin

The case involved Edward Maddox's petition for a writ of habeas corpus under 28 U.S.C. § 2241 after the D.C. Board of Parole revoked his parole based on 1996 firearm possession charges, even though he was acquitted following three trials. Maddox claimed that the same Assistant U.S. Attorney who prosecuted the criminal case improperly acted as prosecutor at the revocation hearing, engaged in ex parte contacts with the Board, and influenced its decision in a vindictive manner, violating due process under the Fifth Amendment. The court found that the AUSA lacked any legal authority to prosecute parole revocation matters, that his role exceeded that of an advocate or witness, and that this unauthorized participation tainted the hearing. The core reasoning focused on the absence of statutory authorization for U.S. Attorneys in parole proceedings, the improper blending of prosecutorial functions, and the resulting deprivation of a fair process.

criminal lawcivil rightsprocedure

In United States v. Jones, the defendant was convicted after a jury trial of one count of possession with intent to distribute heroin, based in part on testimony from a police detective offered as a narcotics expert who described typical drug distribution practices, including the use of stashes and brand names. After the verdict, it was revealed that the detective had lied about his credentials in other proceedings by falsely claiming to hold advanced degrees in pharmacology. The court granted the defendant's motion for a new trial under Federal Rule of Criminal Procedure 33, finding that the newly discovered evidence of the expert's fabricated qualifications was material because his testimony was central to proving intent to distribute and would not have been presented had the facts been known at trial. The court noted that this expert testimony had been the key difference from an earlier trial that ended in a hung jury, while denying an earlier motion raising other grounds.

criminal lawprocedure

This case concerns class counsel from a long-resolved employment discrimination class action seeking to enjoin five former class members from pursuing a malpractice lawsuit against them in D.C. Superior Court. The underlying 1986 class action by African-American Foreign Service Officers against the State Department resulted in a 1996 court-approved consent decree that included injunctive relief, monetary damages, and promotions; some class members objected, sought opt-out rights, and later filed the malpractice suit alleging inadequate representation. The court granted permanent injunctive relief barring the dissident plaintiffs from prosecuting the state court action. The core reasoning was that the malpractice claims would collaterally attack the federal court's prior findings on the settlement's fairness and class counsel's adequacy under Rule 23, and that federal courts may issue such injunctions to protect their judgments and manage comity issues with state courts.

civil rightsprocedurefederal power

This case involved plaintiffs Augustine David Henderson and Gregory Francis Phillips, evangelical Christians who sell message-bearing t-shirts on the National Mall to fund and promote their religious outreach activities, challenging a National Park Service regulation that restricts commercial sales on federal parkland in the National Capital Region to only books, newspapers, leaflets, pamphlets, buttons, and bumper stickers. The plaintiffs claimed the regulation violated the First and Fifth Amendments, the Religious Freedom Restoration Act, and the Administrative Procedure Act. Following the D.C. Circuit's decision in a related case upholding the regulation as constitutional, the district court granted the defendants' motion to dismiss or for summary judgment. The court reasoned that the plaintiffs' free speech and free exercise claims were foreclosed by the appellate precedent, their RFRA claim failed because the regulation did not substantially burden religious exercise or was justified by the government's interest in curbing excessive commercialization on parkland, and their other claims lacked merit.

free speechreligious libertybusiness & regulatory

This case involved a dispute between the District of Columbia Hospital Association and its member hospitals and the District of Columbia over the calculation of Medicaid disproportionate share hospital (DSH) payments. The hospitals challenged the District's policy of excluding Medicaid managed care services from the base amount used in DSH adjustments, arguing it breached representations made in prior 1994 litigation and violated the Medicaid statute. The court addressed cross-motions for summary judgment and judgment on the pleadings, considering issues including res judicata, subject matter jurisdiction, and the District's change in position after earlier assurances that managed care costs would be included. It reasoned that the statute requires inclusion of such services in the base amount and that the District's new formula led to absurd results, such as zero payments for hospitals serving only managed care patients. The opinion also initiated proceedings for potential Rule 11 sanctions against the District.

healthcarefederal power

In this case, news organization A.H. Belo Corporation sought access to 26 tapes and transcripts that the Office of Independent Counsel had identified as potential evidence in its prosecution of former HUD Secretary Henry Cisneros. The materials had been reviewed in camera by the court during a public suppression hearing but were never admitted into evidence, and the case concluded when Cisneros entered a guilty plea. Belo argued for access under both the common law right to judicial records and the First Amendment right of the press. The court denied the application, holding that the materials were not judicial records because they played no definitive role in an adjudicatory decision and that the First Amendment did not require disclosure given the strong privacy interests of Cisneros and third parties after the case ended without a trial.

criminal lawfree speechprocedure

The case concerned defendant Henry G. Cisneros' motion to suppress 26 secretly recorded tapes of his phone conversations with former mistress Linda Medlar, made without his knowledge between 1990 and 1993 and later turned over to prosecutors in copies that included some redactions and omissions. The court denied the motion to suppress the recordings. Its core reasoning was that Medlar, a private party, created the tapes without government involvement, so there was no Title III wiretap violation; the government sufficiently established the tapes' authenticity and reliability for admission despite the copies and redactions; and any issues could be addressed at trial through testimony or further voir dire.

criminal lawprocedure

In Newby v. District of Columbia, a female inmate sued the District after prison guards forced her and other women at the D.C. Jail to perform strip shows and exotic dances, allowed male guards to watch, and after she engaged in a sexual relationship with one guard, all in violation of D.C. law and prior court orders. The court granted the plaintiff's motion for judgment as a matter of law under Fed. R. Civ. P. 50 on liability, finding the undisputed facts showed the District failed to provide adequate supervision in the jail despite a 1994 ruling in a related case that identified a pattern of sexual misconduct and ordered remedial steps. The core reasoning was that the District had a duty under D.C. Code § 24-442 and the Eighth Amendment to protect inmates, yet it did not implement meaningful oversight or monitoring after the prior findings, allowing the misconduct to occur unchecked. The jury was left to decide damages.

civil rightscriminal law

The case involved a nonprofit organization seeking disclosure under the Freedom of Information Act of the names and addresses of individuals who submitted public comments on a proposed rule by the Fish and Wildlife Service regarding the reintroduction of grizzly bears as a nonessential experimental population in the Bitterroot ecosystem. The agency withheld this information under FOIA Exemption 6, citing privacy concerns and potential harassment, though it had released some information for organizational commenters. The court granted summary judgment to the plaintiffs and ordered full disclosure without redaction, reasoning that any privacy interests were not sufficient to outweigh the public interest in access to the comments, that the agency's blanket withholding was improper without individualized assessments, and that its distinction between individual and institutional commenters was arbitrary.

environmentfree speechprocedure

The case involved a challenge by the City of Alexandria, Virginia, and intervenors to the Federal Highway Administration's Record of Decision approving a $1.6 billion project to replace the Woodrow Wilson Bridge with two larger parallel drawbridges, add lanes to connecting interstates, and reconstruct interchanges. Plaintiffs alleged that the environmental review process violated the National Environmental Policy Act (NEPA) by inadequately analyzing alternatives, construction impacts, traffic projections, historic preservation effects, and other environmental consequences in the draft and final environmental impact statements. The court reviewed the administrative record, identified deficiencies in the 1991 DEIS such as insufficient discussion of construction effects and failure to evaluate a ten-lane option, noted the subsequent development of additional alternatives through a coordination process, and addressed related claims under the National Historic Preservation Act. The opinion also referenced a settlement agreement reached between the City of Alexandria and the defendants during the litigation.

environmentfederal power

The case involved determining whether defendant Anual Rudisill was competent to stand trial on federal charges of armed robbery and related firearms offenses, after he suffered severe head trauma and cognitive impairment from an attack by other inmates while in pretrial detention. Following multiple hearings with conflicting psychiatric evaluations from experts including Drs. Johnson, Landis, Garmoe, McCarthy, and Coleman, the court found by a preponderance of the evidence that Rudisill suffered from dementia due to head trauma, had the mental capacity of a young child, and was not competent to stand trial. The court further concluded it was unlikely he would regain competency in the foreseeable future. Based on these findings and 18 U.S.C. § 4241, the court released Rudisill to his mother's custody for continued outpatient care rather than recommitting him to the Attorney General, citing his changed non-violent condition and the need for supervision.

criminal lawprocedure

This case involved a challenge by China Trade Center, LLC to the Washington Metropolitan Area Transit Authority's (WMATA) award of a development contract for the Gallery Place Site in Chinatown to Western Development Corporation following a 1996 request for proposals. WMATA, an interstate agency operating the D.C. metro system, used a negotiated procurement process with multiple rounds of bidding and evaluated proposals on factors including financial viability, impact on ridership, revenue generation, and effects on the local tax base. China Trade alleged that WMATA violated procurement requirements by selecting a non-compliant proposal, showing favoritism, and breaching an implied contract for fair consideration. The court granted WMATA's motion for summary judgment and dismissed the case, finding that WMATA properly exercised its discretion within the RFP's terms, that proposals only needed to demonstrate potential compliance with local land use laws, and that there was no evidence of bias or procedural violations in the scoring and selection process.

business & regulatoryprocedure

This case concerned a dispute over whether D.C. offenders whose parole was revoked were entitled to credit for time spent on parole ("street time") toward their sentences. Petitioner Matthew Noble, a D.C. offender under federal supervision, sought habeas relief after the U.S. Parole Commission denied him such credit under D.C. Code § 24-206(a), despite a later statute, § 24-431, that D.C. authorities had interpreted to require the credit. On remand from the D.C. Circuit, the court held that Noble was subject to the D.C. Court of Appeals' en banc decision in Noble IV, which interpreted the statutes to prohibit credit for revoked parole time. The court reasoned that Noble had no protected reliance interest in the prior contrary practice because he had been supervised by federal authorities, which had consistently followed the no-credit rule, unlike D.C.-supervised offenders.

criminal lawprocedure

The case involves defendant Walter Fleming, who faced charges of distributing cocaine base, carrying a firearm during a drug offense, and unlawful firearm possession by a convicted felon. The court considered motions to suppress surveillance recordings, physical evidence including a gun recovered from the defendant's vehicle, and statements made after arrest. The court suppressed the gun, ruling that agents violated the defendant's Miranda rights by seeking consent to search the vehicle after he invoked his right to counsel. The core reasoning was that all interrogation, including requests eliciting consent forms, must cease once a suspect requests an attorney, rendering the consent and resulting evidence inadmissible.

criminal lawprocedureguns

Metastorm sued Gartner for defamation, trade libel, and tortious interference based on a February 1997 Research Note analyzing the transfer of Novell's InForms electronic forms product to Metastorm, which included statements questioning the product's viability, Metastorm's financial capacity, and the need for users to migrate to alternatives. The court granted Gartner's motion in limine (treated as one for summary judgment on the fault standard), holding that the actual malice standard from New York Times v. Sullivan applies because Metastorm became a limited-purpose public figure by issuing press releases about the Novell agreement and entering the IT market. It denied all parties' summary judgment motions on the claims and counterclaim, finding factual disputes remain that must be resolved at trial under the heightened standard. The core reasoning centered on Metastorm's voluntary participation in a public controversy through media outreach and the constitutional protections for media commentary on business matters of public concern, while noting limits on reckless or knowing falsehoods.

free speechtorts & liabilitybusiness & regulatory

Libbie Rehabilitation Center, a nursing home in Virginia participating in Medicare and Medicaid, sued the Secretary of Health and Human Services after state surveys found ongoing deficiencies, leading the federal government to schedule termination of its provider agreements. The facility sought to convert a temporary restraining order into a preliminary injunction to block the termination pending further review. The court granted the injunction and denied the Secretary's motion to dismiss, finding jurisdiction because of the potential irreparable harm to residents from relocation, a likelihood that Libbie could succeed on its claims regarding the survey process and compliance, and that the balance of harms and public interest favored maintaining the status quo until a new survey and administrative hearing could occur.

healthcarefederal powerbusiness & regulatory

The case involved the American Society of Association Executives, a tax-exempt trade association under 26 U.S.C. § 501(c)(6), seeking a refund of $56,900 in proxy taxes paid on its 1994 lobbying expenditures under 26 U.S.C. §§ 162(e)(3), 162(e)(5)(C), and 6033(e). ASAE argued that these provisions unconstitutionally burdened its and its members' First Amendment rights to free speech, association, and petitioning the government, and violated equal protection under the Fifth Amendment by discriminating against tax-exempt associations compared to individuals and for-profit entities. The court held that the provisions are constitutional both as applied to ASAE and facially, finding they merely deny a tax deduction for lobbying rather than imposing a penalty, do not discriminate based on viewpoint, and are justified by Congress's interest in preventing a subsidy for lobbying activities. It also denied injunctive relief, citing the Anti-Injunction Act's bar on suits to restrain tax collection.

taxesfree speechcivil rightsbusiness & regulatory

The case involved a 21-count indictment charging former HUD Secretary Henry Cisneros, along with Linda Medlar, Sylvia Arce-Garcia, and John Rosales, with conspiracy and related offenses for allegedly making false statements and concealing payments exceeding $250,000 that Cisneros made to Medlar, his former mistress, during his FBI background investigation and Senate confirmation. The defendants filed 21 separate motions to dismiss various counts, arguing grounds such as separation of powers, the political question doctrine, failure to state an offense under 18 U.S.C. §§ 1001 and 1505, immateriality of statements, vagueness, lack of a pending proceeding, and multiplicity. The court reviewed the factual allegations concerning the pre- and post-nomination payments and the scope of federal jurisdiction over statements made to the FBI during the nomination process, applying statutory interpretations including amendments to § 1001 and precedents on what constitutes a department or agency. It addressed each motion by examining whether the indictment sufficiently alleged the elements of the charged offenses based on the described conduct.

criminal lawprocedure

The case concerned whether the Department of Energy was required under the National Environmental Policy Act to prepare a supplemental programmatic environmental impact statement for its Stockpile Stewardship and Management Program, which involved re-establishing plutonium pit production at Los Alamos and building the National Ignition Facility at Lawrence Livermore, in light of new information about potential environmental hazards. Plaintiffs, environmental organizations, argued that changed circumstances necessitated further review, while defendants maintained that existing analyses sufficed. The court denied the plaintiffs' motion for partial summary judgment, granted the defendants' motion with modifications, and dismissed Count II without prejudice, holding that the Department had met its NEPA obligations at the time. The decision included an order directing DOE to determine by January 1, 2004, whether certain experiments required a supplemental PEIS or to prepare one if needed.

environmentfederal power

The Federal Trade Commission brought this action under Section 13(b) of the FTC Act to preliminarily enjoin two proposed mergers—Cardinal Health with Bergen-Brunswig and McKesson with AmeriSource—before the agency could complete an administrative proceeding on whether the transactions would violate the Clayton Act and FTC Act. The four defendant companies are the largest of the roughly forty wholesale distributors of prescription drugs in the United States and, after years of consolidation, the only ones providing nationwide coverage. Following an extensive evidentiary hearing, the district court granted the injunction, finding that the mergers would likely produce undue concentration in the relevant markets and that the defendants had not shown the transactions would not substantially lessen competition. The court relied on evidence of high barriers to entry, including the capital costs and scale required to operate distribution centers, and the limited prospect that new regional entrants could timely replace lost competition.

business & regulatoryhealthcare