Justia Constitutional Law Opinion Summaries

Citing a budget deficit, Chicago’s Board of Education laid off 1,077 teachers and 393 paraprofessional educators in 2011. The Chicago Teachers Union and a class of teachers (CTU) sued, alleging that the layoffs discriminated against African-American teachers and paraprofessionals in violation of Title VII of the Civil Rights Acts of 1964 and the Civil Rights Act of 1991, 42 U.S.C. 2000e.The Seventh Circuit affirmed summary judgment in favor of the Board. While CTU made a prima facie case of disparate impact with evidence that African-Americans comprised approximately 30% of Union members at the time of the layoffs but made up just over 40% of Union members receiving layoff notices, the Board’s decision to tie layoffs to declining enrollment in schools was legitimate, job-related, and consistent with business necessity. Beyond noting the existence of open positions for which laid-off employees were qualified, CTU did not meet its burden of establishing that its proposed alternative of transferring employees was “available, equally valid and less discriminatory.” The Illinois statute’s designation of hiring discretion to principals neither promotes discrimination nor bears any relationship to the Board’s decision to tie layoffs to declining enrollment and the transfer alternative proposed by CTU is not consistent with the Collective Bargaining Agreement. CTU did not put forth any evidence of intentional discrimination by the Board. View "Chicago Teachers Union v. Board of Education of the City of Chicago" on Justia Law

Petitioners Jennifer Pinckney, Howard Duvall, and Kay Patterson challenged the constitutionality of section 10-1-165 of the South Carolina Code (2011). Petitioners also sought an injunction prohibiting enforcement of section 10- 1-165. The South Carolina Supreme Court granted the petition to hear the case in its original jurisdiction and found unconstitutional the procedural provision in subsection 10-1-165(B) purporting to restrict the General Assembly's legislative power by imposing a supermajority voting requirement to amend or repeal section 10-1-165. The Court found no constitutional violation in the substantive provisions in subsection 10-1-165(A) preventing the relocation, removal, renaming, or rededication of monuments, memorials, streets, bridges, parks, or other structures. The Court denied petitioners' request for an injunction. View "Pinckney v. Peeler" on Justia Law

Smith, a Muslim serving a life sentence, sued the Georgia Department of Corrections (GDOC) under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc, claiming that GDOC’s grooming policy, which prohibits inmates from growing facial hair over a half-inch in length, placed a substantial burden on his religious exercise. The district court rejected Smith’s RLUIPA claim, finding that “GDOC ha[d] offered logical and persuasive reasons to show that allowing untrimmed beards would be unmanageable for GDOC” and that “it is plausible that allowing a close security inmate like Smith an untrimmed beard could be dangerous for prison security.” Rather than rule in favor of GDOC, the district court fashioned a remedy that neither party had requested: it held that RLUIPA entitled Smith to grow a three-inch beard.The Eleventh Circuit vacated. The district court’s determination that it was reasonable for GDOC to conclude that allowing Smith to grow an untrimmed beard would be both unmanageable and dangerous was not clearly erroneous but its ruling requiring GDOC to allow Smith to grow a three-inch beard was improper and contrary to the Supreme Court’s 2015 holding, Holt v. Hobbs, that courts should consider only the plaintiff’s proposed alternatives in deciding whether there is an available less restrictive means for the government to further its compelling interests under RLUIPA. View "Smith v. Dozier" on Justia Law

Devereux suffered a major stroke during or around the period of his custody by Knox County for misdemeanor first-time DUI. Corrections officers were in and out of the holding cell where he sat motionless for several hours but did not provide medical attention until it was too late to mitigate the stroke’s effects. Devereux brought federal civil rights claims and negligence claims under the Tennessee Governmental Tort Liability Act (TGTLA), which waives sovereign immunity for certain claims, but not those arising from “civil rights.”The district court dismissed all of Devereux’s claims against the officers and his civil rights claims against Knox County. It declined to exercise supplemental jurisdiction over the TGTLA claims and dismissed them without prejudice, allowing Devereux to refile in state court. Knox County argued that the court should have retained jurisdiction and determined that the TGTLA’s “civil rights exception” necessarily barred Devereux’s negligence claims. The Sixth Circuit vacated in part. The best approach is to give Tennessee courts a fresh opportunity to consider whether the TGTLA claims ivolve civil rights. The court vacated “to prevent any issue of collateral estoppel in state court based on this aspect of the district court’s reasoning. The court declined to certify the issue to the Tennesse Supreme Court. View "Devereux v. Knox County" on Justia Law

Brawner was detained at the Scott County jail. On her written questionnaire, Brawner answered that she needed to continue her prescription medications, listing three controlled substances: suboxone, clonazepam, and gabapentin. She denied having a serious medical condition that required attention and denied having epileptic seizures. The officer noted that Brawner did not appear capable of understanding all the questions. There is conflicting evidence about whether Brawner’s intake form ever made it to the jail nurse. Days later, Brawner suffered multiple seizures and was taken to a hospital. A treating physician diagnosed her with epilepsy and prescribed Phenobarbital. The hospital was not told that Brawner had not been permitted to take her prescribed medications. At the jail doctor’s instruction, jail nurse Massengale discontinued Brawner’s Phenobarbital and instead administered Dilantin. Over the next several days, Brawner suffered multiple seizures before finally being taken to a hospital.Brawner sued, claiming she suffered permanent, debilitating injuries. The Sixth Circuit reinstated two of her claims. A reasonable jury could find that Brawner had an objectively serious medical need, and that Massengale was either subjectively aware of the risk to Brawner from suddenly discontinuing her medications, in keeping with County policy against distributing controlled substances at the jail and failed to respond reasonably to that risk, or that Massengale recklessly failed to act reasonably to mitigate that risk, by following a policy that allowed the jail to wait 14 days before conducting a medical examination. View "Brawner v. Scott County" on Justia Law

Marshall, while under the age of 21, wished to purchase a handgun from a federally licensed firearms dealer and sued to challenge the constitutionality of the federal laws and regulations that prohibited her from doing so while she was 18–20 years old. A divided panel of the Fourth Circuit found those laws violated the text, structure, history, and tradition of the Second Amendment. After the opinion was issued but before the mandate, Marshall turned 21, rendering her claims moot. She attempted to add parties and reframe her claimed injuries.The Fourth Circuit concluded that it is too late to revive the case and that it must be dismissed as moot. The court vacated the opinions and remanded with direction to dismiss. View "Hirschfeld v. Bureau of Alcohol, Firearms, Tobacco & Firearms" on Justia Law

At initial hearings, New Jersey's Parole Board may consult any information it deems relevant, including an inmate’s criminal history. At successive parole hearings, the Board could not consider old information, including the inmate's criminal history. The 1997 Amendments to the Parole Act eliminated that prohibition and instructed the Board to prepare an “objective risk assessment” before every parole hearing, incorporating old information, including an inmate’s “educational and employment history” and “family and marital history,” and other factors. When Holmes was on parole in the 1970s, he killed two acquaintances, murdered a 69-year-old, and wounded a police officer. Sentenced to life in prison with the possibility of parole, Holmes remains behind bars 48 years later. At his initial parole hearing in 2001, the Board refused to release Holmes. After a 2012, hearing, the Board issued a detailed written statement that probed Holmes’s past parole violations, highlighted the homicides, and scrutinized the shootout that preceded his arrest. The statement noted his unblemished disciplinary record since his initial parole hearing. Without specifying the weight placed on each factor, the Board rejected Holmes’s request for release.Holmes challenged the decision on ex post facto grounds. The Third Circuit vacated the dismissal of his petition. For many prisoners, the rules present little risk to their parole prospects. For Holmes, the change plausibly produced a significant risk of prolonging his time behind bars. View "Holmes v. Christie" on Justia Law

At some time in the early morning hours of December 27, 1996, Appellant entered his estranged wife Carla’s home and then shot Carla and her fourteen-year-old daughter D.M. in the head, killing both of them. The Commonwealth charged Appellant with one count of burglary and two counts of first-degree murder. A jury found Appellant guilty of those charges. After a penalty hearing, the jury sentenced Appellant to death on both of his murder convictions. On July 17, 2014, the PCRA court entered an order dismissing another handful of Appellant’s claims based upon the evidence presented in the initial evidentiary hearing. The Pennsylvania Supreme Court affirmed that order in all respects, save one. "Respectfully, the PCRA court did not provide its rationale for rejecting the fact-intensive issue relating to Appellant’s competency to proceed to trial and represent himself and prior counsels’ alleged ineffectiveness for failing to pursue the issue." Consequently, this matter was remanded to the PCRA court solely to issue a supplemental opinion addressing its reasons for denying relief on these claims. View "Pennsylvania v. Reid" on Justia Law

The issue in this case is whether the trial court should have permitted Appellant Jose Sanchez to withdraw his waiver of a jury trial that was executed in anticipation of a negotiated plea that was never consummated. After overruling several requests by Appellant to withdraw his jury waiver, the trial court afforded him a bench trial. The Texas Court of Criminal Appeals concluded the trial court abused its discretion by failing to permit the withdrawal of appellant’s jury-trial waiver. Judgment was reversed and the matter remanded for further proceedings. View "Sanchez v. Texas" on Justia Law

A confidential informant employed by a police agency arranged to purchase methamphetamine from Appellant Darren Biggers. When Appellant arrived in his vehicle at the arranged place and time, officers detained him for a narcotics investigation. The investigating officer saw a Sprite bottle and a white Styrofoam cup, both filled with “a purple-type substance.” Appellant admitted that it was “lean” (a term for codeine cough syrup mixed in a beverage). The substance field-tested positive for codeine, and officers arrested Appellant for possession of a controlled substance. The State charged Applicant with possession of a Penalty Group 4 controlled substance (codeine) in an amount over 400 grams. During the State’s case-in-chief, the State proffered testimony from a chemist regarding the contents of the Sprite bottle and a Styrofoam cup. The chemist explained that she was not asked to quantify the amount of codeine and promethazine in the Sprite bottle or the Styrofoam cup, and she did not know the concentration level of codeine in either sample. The chemist testified that promethazine was a nonnarcotic active medicinal ingredient, but she never testified as to “whether the combination of promethazine and codeine had valuable medicinal qualities other than those possessed by the codeine alone.” On appeal, Appellant argued that, at best, the State only established the mere presence of promethazine, and that by failing to prove the level of concentration of codeine in the substances possessed by Appellant, as required by the statute, the State failed to establish an essential element of the offense. The court of appeals agreed, finding the evidence was insufficient to establish that (1) the concentration level of the codeine was not more than 200 milligrams of codeine per 100 milliliters, and (2) the presence of promethazine was in a sufficient proportion to convey on the mixture valuable medicinal qualities other than those possessed by the codeine alone. The Texas Court of Criminal Appeals concurred the evidence was insufficient to prove that Appellant possessed Penalty Group 4 codeine, but was not negated beyond a reasonable doubt as required for Penalty Group 1 codeine, therefore the Court held Appellant did not possess Penalty Group 1 codeine. The Court agreed with the court of appeals that Appellant was entitled to an acquittal. View "Biggers v. Texas" on Justia Law