Justia Civil Rights Opinion Summaries

Articles Posted in Constitutional Law
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In the case under review, the plaintiff-appellant, Thomas Eugene Creech, currently on death row for the 1981 murder of David Dale Jensen, had sought commutation of his death sentence. The State of Idaho had granted Creech a commutation hearing before the Commission of Pardons and Parole, which ultimately denied his petition. Consequently, Creech filed a § 1983 action in federal court, alleging various due process violations during the commutation proceedings and sought a preliminary injunction. The United States District Court for the District of Idaho denied his motion, and he appealed.The United States Court of Appeals for the Ninth Circuit affirmed the lower court's decision. The Court held that the state had met the minimal procedural safeguards required by the Due Process Clause of the Fourteenth Amendment in the commutation proceedings. It rejected Creech's arguments that he was not given adequate notice of the issues to be considered by the Commission and the evidence to be presented at the commutation hearing. Additionally, the Court found that Creech was not entitled to the appointment of a replacement commissioner when one Commissioner recused himself. The Court also refuted Creech's claims that the Ada County Prosecuting Attorney’s Office violated his due process rights by suggesting to the Commission that Creech had committed another murder and got away with it, and by introducing misleading or fabricated evidence during the hearing. The Court found no violation or arbitrariness that would warrant judicial intervention. View "CREECH V. BENNETTS" on Justia Law

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In November 2018, Joseph Hoskins was stopped by a Utah state trooper, Jared Withers, because his Illinois license plate was partially obscured. The situation escalated when Trooper Withers conducted a dog sniff of the car, which led him to search the car and find a large amount of cash. Mr. Hoskins was arrested, and his DNA was collected. Mr. Hoskins sued Trooper Withers and Jess Anderson, Commissioner of the Utah Department of Public Safety, alleging violations of the First and Fourth Amendments and state law.The United States Court of Appeals for the Tenth Circuit held that Trooper Withers had reasonable suspicion to conduct the traffic stop because Utah law requires license plates to be legible, and this applies to out-of-state plates. The court also found that the dog sniff did not unlawfully prolong the traffic stop, as Mr. Hoskins was searching for his proof of insurance at the time. The court ruled that the trooper's protective measures, including pointing a gun at Mr. Hoskins, handcuffing him, and conducting a patdown, did not elevate the stop into an arrest due to Mr. Hoskins's confrontational behavior.The court further held that the dog's reaction to the car created arguable probable cause to search the car and that the discovery of a large amount of cash provided arguable probable cause to arrest Mr. Hoskins. The court found that Trooper Withers did not violate any clearly established constitutional rights by pointing a gun at Mr. Hoskins in retaliation for protected speech or as excessive force. Lastly, the court found no violation of Mr. Hoskins's due process rights related to the handling of his DNA sample, as neither the Due Process Clause nor state law created a protected interest in a procedure to ensure the destruction of his DNA sample. View "Hoskins v. Withers" on Justia Law

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In October 2018, Warren G. Treme, a member of AJSJS Development, LLC, leased minerals on a tract of land in St. John the Baptist Parish, Louisiana, from Dr. Christy Montegut and his siblings. AJSJS intended to join a joint venture formed in 2010 between Treme, AIMS Group, Inc., and Fred Kinsley. The joint venture aimed to extract and process clay material from the tract for a U.S. Army Corps of Engineers project. However, to conduct mining and excavation activities, the plaintiffs needed to change the zoning classification of the tract. Despite multiple applications for rezoning, the Parish Council denied the applications after hearing complaints from affected residents. The plaintiffs then sued the Parish and the Council, alleging that the denial of the rezoning application constituted a regulatory taking without compensation in violation of the United States and Louisiana Constitutions. The plaintiffs also alleged violations of procedural and substantive due process and equal protection rights under the Fourteenth Amendment.The United States Court of Appeals for the Fifth Circuit held that the plaintiffs lacked standing to bring a takings claim because their mineral lease was not yet in effect, meaning they had no vested property interest in the tract. The court interpreted the lease to have a suspensive condition that required the plaintiffs to obtain governmental approvals for the lease to become effective. As the plaintiffs had not obtained these approvals, the lease had not yet come into effect. Consequently, the court affirmed the district court’s decision but modified the judgment to be a dismissal without prejudice. View "Treme v. St. John the Baptist" on Justia Law

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In the State of Nevada, Alexander M. Falconi, operating as the press organization Our Nevada Judges, petitioned against the Eighth Judicial District Court, the Honorable Charles J. Hoskin, District Judge, and parties in interest, Troy A. Minter and Jennifer R. Easler. Falconi challenged local rules and a statute that required certain court proceedings to be closed to the public.Falconi filed a media request for camera access in a child custody proceeding between Minter and Easler. Minter opposed the request, arguing it was not in the child's best interest to have his personal information publicly available. The district court denied Falconi's request, citing that the case was sealed and thus required to be private according to local rules.The Supreme Court of the State of Nevada held that the public has a constitutional right to access court proceedings. The local rules and the statute, NRS 125.080, requiring the district court to close proceedings, bypassed the exercise of judicial discretion and were not narrowly tailored to serve a compelling interest. Thus, the court held that these local rules and NRS 125.080 were unconstitutional to the extent they permitted closed family court proceedings without exercising judicial discretion.The court instructed the district court to reverse its order denying media access in the underlying child custody case. The court emphasized the importance of public access to court proceedings, including family court proceedings, which historically have been open to the public. The court rejected the automatic closure of such proceedings and emphasized the necessity of case-by-case judicial discretion in deciding whether to close proceedings. View "Falconi v. Eighth Jud. Dist. Ct." on Justia Law

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In the case at hand, the United States Court of Appeals for the Third Circuit affirmed the dismissal of claims brought by a group of students and Children’s Health Defense, Inc. against Rutgers University. The plaintiffs challenged the university's COVID-19 vaccination policy, which required in-person students to be vaccinated or else enroll in online programs or seek exemptions for medical or religious reasons. The court found that the university's policy did not violate the plaintiffs' constitutional or statutory rights.The court held that there is no fundamental right to refuse vaccination. It applied the rational basis review and concluded that Rutgers University had a rational basis for its policy given the challenges posed by the COVID-19 pandemic. The court also rejected the plaintiffs' claim that the policy was ultra vires under New Jersey law, determining that Rutgers was authorized to require COVID-19 vaccinations under state law. Furthermore, the court dismissed the plaintiffs' equal protection claim, concluding that Rutgers had a rational basis for its differential treatment of students and staff, as well as vaccinated and unvaccinated students. View "Children's Health Defense Inc. v. Rutgers, the State University of New Jersey" on Justia Law

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This case involves a dispute over the interpretation of the federal Law Enforcement Officers Safety Act of 2004 (LEOSA), which allows certain qualified retired law enforcement officers to carry concealed firearms, and its relation to New Jersey’s more restrictive retired police officer permitting law. The retired law enforcement officers from various agencies claimed that LEOSA provided them with a federal right to carry concealed firearms in New Jersey, superseding the state law. The State of New Jersey argued that LEOSA did not provide an enforceable right and, if it did, it would only apply to officers who retired from federal or out-of-state law enforcement agencies—not to officers who retired from New Jersey law enforcement agencies.The United States Court of Appeals for the Third Circuit held that LEOSA does provide certain retired officers who meet all the statutory requirements with an enforceable right, and that right extends equally to officers who retired from New Jersey agencies and those who retired from federal or out-of-state agencies. The court held that the federal statute also preempts contrary aspects of New Jersey law. Therefore, the court affirmed the District Court’s order granting declaratory and injunctive relief to the retired officers, allowing them to carry concealed firearms. View "Federal Law Enforcement Officers Association v. Attorney General New Jersey" on Justia Law

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In a case before the United States Court of Appeals for the Third Circuit, a group of former union members alleged that their First Amendment rights were violated when their respective unions continued to deduct membership dues from their paychecks after they had resigned from the unions. The appellants had previously signed union membership applications authorizing the deduction of dues from their paychecks, with the authorizations being irrevocable for a year, regardless of membership status, unless the member provided written notice of revocation within a specified annual window. The appellants resigned from their respective unions after their annual revocation windows had passed, and the unions continued to deduct dues until the next annual revocation window. The appellants argued that the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, which held that public-sector unions charging fees to nonmembers is a form of coerced speech that violates the First Amendment, should extend to their situation. The Third Circuit disagreed, holding that Janus was focused on preventing forced speech by nonmembers who never consented to join a union, not members who voluntarily join a union and later resign. The court further rejected the appellants' due process claims, finding that they had not been deprived of any constitutional rights. The court also dismissed the appellants' contract defenses, finding that they had not alleged that the terms of their original membership agreements entitled them to membership in perpetuity. The court affirmed the District Court's orders dismissing the appellants' claims. View "Fultz v. AFSCME" on Justia Law

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In the case at hand, DeWitt Lamar Long, a practicing Muslim and inmate at Halawa Correctional Facility in Hawaii, brought a legal action against several prison officials under 42 U.S.C. § 1983. He alleged that his First Amendment rights to freely exercise his religion were violated and that he was unconstitutionally retaliated against for engaging in protected First Amendment activity. Specifically, Long claimed that he was denied meals consistent with his Islamic faith, that his meal during Ramadan was delivered early and thus was cold and potentially unsafe by the time he could break his fast, and that he was transferred from a medium-security facility to a high-security facility in retaliation for filing grievances.The United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, and vacated in part the district court’s judgment. The appellate court found that the district court erred in dismissing Long's claims for injunctive relief without allowing him a chance to amend his complaint to demonstrate the need for such relief. The court also vacated the district court’s decision to grant summary judgment in favor of Sergeant Lee, holding that the delivery of Long's evening meal at 3:30 p.m. during Ramadan substantially burdened his free exercise of religion. The court remanded the case to allow the district court to evaluate whether the burden was justified.However, the appellate court affirmed the district court's summary judgment in favor of Chief of Security Antonio regarding Long’s claim that he was transferred from a medium-security facility to a high-security facility in retaliation for filing grievances. The court agreed with the district court that the sequence of events leading to the transfer was insufficient to show retaliatory intent. The court also affirmed the district court’s judgment after a bench trial in favor of Sergeant Sugai and Chief of Security Antonio on Long’s free exercise of religion and retaliation claims. View "LONG V. SUGAI" on Justia Law

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In a case before the Supreme Court of New Hampshire, the plaintiffs, two police officers injured in a shooting, filed a suit against Chester Arms, LLC (the seller of the firearm used in the shooting), and the New Hampshire Department of Safety (DOS) (which conducted the background check for the sale of the firearm). The suit accused Chester Arms of negligent entrustment and DOS of negligent entrustment and negligence per se. The trial court granted summary judgment in favor of both defendants on the basis of immunity under state law. The court of appeals affirmed the lower court's decision.The court of appeals found that the state law barring lawsuits against firearms manufacturers and sellers for damages resulting from the criminal or unlawful use of their products by a third party was constitutional and not preempted by federal law. The court found that the law was designed to safeguard citizens' fundamental right to bear arms by limiting suits against the firearms industry, thereby protecting its solvency and ensuring law-abiding citizens have access to firearms. The court also found that the law did not violate the plaintiffs' constitutional right to equal protection or right to a remedy.Regarding the suit against DOS, the court found that DOS had not been negligent in its background check as the shooter was not disqualified from owning a firearm at the relevant time under federal law. Therefore, the court concluded that any alleged error in the trial court's immunity analysis was harmless as DOS was entitled to judgment as a matter of law. View "Hardy v. Chester Arms, LLC" on Justia Law

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In a case before the United States Court of Appeals for the Fifth Circuit, the parents of Ashtian Barnes, who was fatally shot by Officer Roberto Felix, Jr. during a lawful traffic stop, alleged violations under 42 U.S.C. § 1983 against Officer Felix and Harris County. The parents argued that Officer Felix's use of force was unreasonable because even if Barnes attempted to flee, he did not pose a threat justifying deadly force. The district court granted the defendants' motion for summary judgement, stating that Officer Felix did not violate Barnes's constitutional rights and was entitled to qualified immunity. The district court found that Barnes posed a threat of serious harm to Officer Felix in the moment the car began to move, thus making Officer Felix's use of deadly force reasonable and not excessive. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court's judgment, concluding that under the Circuit's precedent on the "moment of threat" analysis, there was no violation of Barnes's constitutional rights. Consequently, the court also affirmed the grant of summary judgement to Harris County, as there was no finding of constitutional injury. View "Barnes v. Felix" on Justia Law