Justia Constitutional Law Opinion Summaries

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In a prior criminal action, the state court agreed with the plaintiff in this case that Defendant Chapman, a Medical Board investigator, used illegally-obtained files to fabricate evidence and to indict plaintiff on trumped-up charges of running a pill mill. Here, plaintiff filed a civil suit under 42 U.S.C. 1983 against Chapman and another government agent for violating his constitutional rights by using instanter subpoenas to illegally search his clinic, resulting in the illegal seizure of property and patient records. The Fifth Circuit reversed the district court's judgment and held that Chapman was not entitled to absolute immunity as an investigator and, because Chapman fulfilled the fact-finding role generally filled by law enforcement, she is only entitled to the level of immunity available to law enforcement -- qualified immunity. The court also held that malicious prosecution and abuse of process are not viable theories of constitutional injury. The court agreed with defendants that malicious prosecution and abuse of process are torts, not constitutional violations. However, the court remanded for the district court to decide whether plaintiff has waived his Fourth Amendment claims and whether he should be allowed to amend his complaint a third time to add a due process claim. View "Morgan v. Chapman" on Justia Law

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Plaintiff, a recent high school graduate and a transgender young man, filed suit against the school board through his next friend and mother, alleging violations of his rights under Title IX of the Education Amendments Act of 1972 and the Fourteenth Amendment to the U.S. Constitution. The Eleventh Circuit affirmed the district court's judgment granting plaintiff relief on both claims and held that the school district's policy barring plaintiff from the boys' restroom does not square with the Constitution's guarantee of equal protection and Title IX's prohibition of sex discrimination. Applying heightened scrutiny, the court held that the record does not demonstrate that the school board has met its "demanding" constitutional burden by showing a substantial relationship between excluding transgender students from communal restrooms and student privacy. In this case, the policy is administered arbitrarily; the school board's privacy concerns about plaintiff's use of the boys' bathroom are merely hypothesized, with no support in the factual record; and the bathroom policy subjects plaintiff to unfavorable treatment simply because he defies gender stereotypes as a transgender person. Therefore, because the record reveals no substantial relationship between privacy in the school district restrooms and excluding plaintiff from the boys' restroom, the bathroom policy violates the Equal Protection Clause. Applying the Supreme Court's recent decision in Bostock v. Clayton County, 590 U.S. ___, 140 S. Ct. 1731 (2020), the court held that excluding plaintiff from the boys' bathroom amounts to sex discrimination in violation of Title IX. The court explained that Title IX protects students from discrimination based on their transgender status; the school district treated plaintiff differently because of his transgender status and this different treatment caused him harm; and nothing in Title IX's regulations or any administrative guidance on Title IX excuses the discriminatory policy. Furthermore, plaintiff's discrimination claim does not contradict Title IX's implementing regulation. View "Adams v. School Board of St. Johns County" on Justia Law

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Defendant Leon Tacardon was charged with possession of a controlled substance for sale, and misdemeanor possession of marijuana for sale. Evidence of these crimes was seized following an interaction with San Joaquin County Sheriff’s Deputy Joel Grubb. After an unsuccessful motion to suppress evidence made during the preliminary hearing under Penal Code section 1538.5, defendant renewed his motion under Penal Code section 995, and prevailed. The State appealed. Based on the magistrate’s factual findings expressed on the record and supported by substantial evidence, the Court of Appeal concluded defendant was detained by Deputy Grubb not when the deputy detained defendant's passenger, M.K., but when the deputy, after smelling marijuana coming from the BMW and seeing three large bags of the substance on the rear floorboard, told defendant to remain in the car while he conducted a records check. "At that point, there can be no doubt the deputy possessed reasonable suspicion defendant was engaged in criminal activity." The Court concluded the superior court erred by setting aside the magistrate’s ruling denying defendant’s motion to suppress evidence. View "California v. Tacardon" on Justia Law

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A brief encounter between two groups of strangers in a restaurant parking lot at closing time ended in one man shot and killed. Three others were injured. Pedro Cardenas was one of the shooters, and convicted by jury trial on one count of murder, two counts of attempted murder, and one count of assault with a firearm, and he pled guilty to one count of being a felon in possession of a firearm. The trial court instructed the jury on the "kill zone" theory as to the attempted murder counts. On the felon in possession count, Cardenas argued that his rights under California v. Arbuckle, 22 Cal.3d 749 (1978) were violated because he was sentenced by a different judge from the one who took his guilty plea. Cardenas did not object on that basis at sentencing, but he cited California v. Bueno, 32 Cal.App.5th 342 (2019) for the proposition that he did not thereby forfeit the issue. A split Court of Appeal concluded that the evidence was insufficient to justify instructing on the kill zone theory under California v. Canizales, 7 Cal.5th 591 (2019), and the error was prejudicial. The Court therefore vacated the attempted murder convictions. The Court disagreed with Bueno and held that Cardenas forfeited the Arbuckle issue by failing to raise it at sentencing. The Court affirmed in all other respects. View "California v. Cardenas" on Justia Law

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The Fifth Circuit reversed the district court's denial of habeas relief under 28 U.S.C. 2254(d) based on a Confrontation Clause violation. Petitioner was convicted by a jury of armed robbery and aggravated battery. The court first held that the state intentionally waived its defense of procedural default. The court also held that the state district court's decision that no Confrontation Clause violation occurred through the handling of a detective's testimony constitutes an unreasonable application of Supreme Court precedent, and the state waived harmlessness. In this case, the detective testified that a nontestifying witness implicated petitioner and the prosecution likewise referenced that testimony in its closing argument. Therefore, such testimony violates the Confrontation Clause. The court remanded for the district court to grant habeas relief. View "Atkins v. Hooper" on Justia Law

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PCMA filed suit claiming that the Employee Retirement Income Security Act of 1974 (ERISA) and the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (Medicare Part D), preempt two sections of the North Dakota Century Code regulating the relationship between pharmacies, pharmacy benefits managers (PBMs), and other third parties that finance personal health services. The district court determined that only one provision in the legislation was preempted by Medicare Part D and entered judgment in favor of North Dakota on the remainder of PCMA's claims. The Eighth Circuit held that it need not address the "connection with" element of the analysis because the legislation is preempted due to its impermissible "reference to" ERISA plans. In this case, the legislation is preempted because its references to "third-party payers" and "plan sponsors" impermissibly relate to ERISA benefit plans. Therefore, the court held that the North Dakota legislation is preempted because it "relates to" ERISA plans "by regulating the conduct of PBMs administering or managing pharmacy benefits." Finally, the court held that North Dakota waived its savings clause argument. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Pharmaceutical Care Management Ass'n v. Tufte" on Justia Law

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Defendants appealed the district court's grant of a preliminary injunction preventing enforcement of four state laws that regulate abortion: the Arkansas Unborn Child Protection from Dismemberment Abortion Act, the Sex Discrimination by Abortion Prohibition Act, an amendment concerning the disposition of fetal remains, and an amendment concerning the maintenance of forensic samples from abortions performed on a child. On June 29, 2020, the Supreme Court issued its opinion in June Medical Services L. L. C. v. Russo, 140 S. Ct. 2103 (2020), holding unconstitutional a Louisiana law requiring doctors who perform abortions to have admitting privileges at a nearby hospital. The Eighth Circuit vacated the district court's preliminary injunction and remanded for reconsideration in light of Chief Justice Roberts's separate opinion in June Medical, which is controlling, as well as the Supreme Court's decision in Box v. Planned Parenthood of Ind. & Ky., Inc., 139 S. Ct. 1780 (2019) (per curiam). View "Hopkins v. Jegley" on Justia Law

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On petition for rehearing en banc, the en banc court held that the Committee on the Judiciary of the House of Representatives has standing under Article III of the Constitution to seek judicial enforcement of its duly issued subpoena. This case arose when the Committee began an investigation into alleged misconduct by President Trump and his close advisors. The Committee requested that Donald F. McGahn, II turn over documents related to the President's alleged obstruction of Special Counsel Robert S. Mueller's investigation. When McGahn, then no longer White House Counsel, declined these requests, the Committee issued a subpoena ordering McGahn to appear at a hearing to testify and to produce the requested documents. The en banc court held that the Committee, acting on behalf of the full House of Representatives, has shown that it suffers a concrete and particularized injury when denied the opportunity to obtain information necessary to the legislative, oversight, and impeachment functions of the House, and that its injury would be redressed by the order it seeks from the court. The court explained that the ordinary and effective functioning of the Legislative Branch critically depends on the legislative prerogative to obtain information, and constitutional structure and historical practice support judicial enforcement of congressional subpoenas when necessary. Therefore, the court affirmed the judgment of the district court in part. View "Committee on the Judiciary of the United States House of Representatives v. McGahn" on Justia Law

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The Eleventh Circuit affirmed the district court's dismissal of a 28 U.S.C. 2254 petition for writ of habeas corpus based on lack of jurisdiction as an unauthorized second or successive petition. In this case, the state trial court granted in part petitioner's motion to correct sentence, pursuant to Fla. R. Crim. P. 3.800(a), and issued an amended sentence nunc pro tunc, which removed a 10-year mandatory minimum term on one of his counts of conviction. The court held that the district court properly determined that petitioner's latest section 2254 petition was an unauthorized second or successive petition over which it lacked jurisdiction. The court explained that, because the amended sentence was entered nunc pro tunc under Florida law, it related back to the date of the original judgment and it was not a "new judgment" for purposes of section 2244(b). View "Osbourne v. Secretary, Florida Department of Corrections" on Justia Law

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Liggins violated the terms of his probation multiple times; each time it was reinstated with modified terms. Police responded to an alleged altercation between Liggins and his girlfriend, Roy, at 4:00 o’clock in the morning. Roy was found outside a San Francisco convenience store crying and yelling. She told officers Liggins had punched, kicked, and choked her. After the fight, Liggins apparently rode away on his bicycle. Roy’s behavior was unruly, characterized by screaming and cursing. Officers arrested Liggins. By the time of Liggins’s preliminary hearing, his former attorney stated that Roy had recanted her accusations against Liggins; her erratic behavior at the scene of Liggins’s arrest, Roy told his attorney, resulted from her being under the influence of a controlled substance and her failure to take prescribed medication for manic-depression. At the probation revocation hearing, Liggins’s attorney asserted hearsay objections to the admission of an officer’s body camera footage, which captured Roy making statements about Liggins’s conduct, and an officer’s testimony to Roy’s statement identifying Liggins. The objections were overruled. The court revoked Liggins’s probation and sentenced him to three years in prison. The court of appeal reversed. While the trial court was within its discretion to admit the challenged statements under the spontaneous statement exception, their admission in the absence of a showing of Roy’s unavailability or other good cause to present hearsay in lieu of live testimony from her violated Liggins’s due process right of confrontation. View "People v. Liggins" on Justia Law