Justia Constitutional Law Opinion Summaries

Plaintiffs, black citizens of Misssissippi who have lost their right to vote in Mississippi because they were convicted of crimes enumerated in section 241 of the Mississippi Constitution, filed suit alleging that section 241 violates the Fourteenth Amendment because it was enacted with a discriminatory purpose.After determining that plaintiffs have Article III standing and that the suit is not barred by sovereign immunity, the Fifth Circuit agreed with the district court that per Cotton v. Fordice, 157 F.3d 388 (5th Cir. 1998), the discriminatory taint of the 1890 provision was removed by the amendment processes in 1950 and 1968. Furthermore, under the rule of orderliness, the court was bound by that decision. Accordingly, the court affirmed the district court's grant of summary judgment for the Secretary of State. View "Harness v. Hosemann" on Justia Law

Joiner is a 31‐year‐old prisoner serving an eight-year sentence at U.S. Penitentiary Marion for a drug crime. In July 2020, amid the COVID‐19 pandemic, Joiner sought compassionate release under 18 U.S.C. 3582(c)(1)(A), citing “extraordinary and compelling reasons,” self‐reported hypertension, a body mass index (BMI) of 28.9 (the “over‐weight” category), and his skin color. He argued that Black Americans have disproportionately suffered from COVID‐19 because “society has put them in worse positions.” He cited a CDC article to argue that Black people in the U.S. face a higher risk of hospitalization and death from COVID‐19, and other articles to contend that, even though skin color should not affect health outcomes from infectious diseases, “our society” delivers subpar health care to “people with black skin,” even when controlling for class, comorbidities, and access to health insurance. The government contended that Joiner’s medical records did not contain evidence of hypertension and that his BMI did not place him at “high risk” for severe COVID‐19 complications.The district court ruled that Joiner did not present extraordinary and compelling reasons for release, without comment on Joiner’s racial disparity argument. The Seventh Circuit affirmed. The cited articles identify multiple societal factors that are not relevant to Joiner’s individual situation in federal prison. Without any factual basis tying those broader societal concerns to Joiner’s individual situation, the district court was not required to address the argument. View "United States v. Joiner" on Justia Law

Defendant-appellant Ronald Benton was convicted by jury of one count of possession of a firearm by a person convicted of a misdemeanor crime of domestic violence. The district court imposed a sentence based on the penalty found in 18 U.S.C. 924(a)(2). Benton challenges his conviction on multiple grounds. The Tenth Circuit found that each of those grounds was predicated on accepting his proposed interpretation of the Supreme Court’s decision in Rehaif v. United States, 139 S. Ct. 2191 (2019). Specifically, Benton argued that, under Rehaif, the government was required to prove not only that he knew he was a domestic violence misdemeanant, but also that he knew that status prohibited him from possessing a firearm. Benton contended his conviction had to be vacated because the jury was not instructed it must find he knew he was prohibited from possessing a firearm, and because the government presented insufficient evidence concerning his knowledge that he was so prohibited. To this, the Tenth Circuit rejected Benton’s interpretation of Rehaif, holding that in a prosecution under sections 922(g) and 924(a)(2), the government need not prove a defendant knew his status under section 922(g) prohibited him from possessing a firearm. Instead, the only knowledge required for conviction was that the defendant knew: (1) he possessed a firearm; and (2) had the relevant status under section 922(g) at the time of his possession. Because the Court rejected Benton’s proposed interpretation of Rehaif, the Court further rejected his challenges to the jury instructions and the sufficiency of the evidence. View "United States v. Benton" on Justia Law

Defendant Joseph Jackson sought a youth offender parole hearing under California Penal Code section 3051 as a result of his conviction in 1998 that included two counts of first degree murder with multiple special circumstances, which counts resulted in a sentence of two consecutive terms of life without the possibility of parole (LWOP). Defendant was 19 years old when he committed the homicides. In his October 2019 motion, defendant argued section 3051 violated his equal protection rights because he allegedly “is entitled to the same protections as any other person who violated the law at the same age whether it was murder without special circumstances, robbery, kidnapping or any other crime.” The trial court denied the motion, finding that defendant was statutorily ineligible for relief and that there was a rational basis for carving out from section 3051 offenders such as defendant who are convicted of first degree special circumstance murder and sentenced to LWOP. On appeal, defendant reasserted section 3051’s exclusion of persons over 18 years of age with LWOP sentences from its parole hearing provisions violated the constitutional guarantee of equal protection. The Court of Appeal independently concluded the carve out to section 3051 for offenders such as defendant serving a LWOP sentence for special circumstance murder was not an equal protection violation. View "California v. Jackson" on Justia Law

Plaintiff filed suit against Foster Farms for its allegedly misleading labels and against American Humane for its allegedly negligent certification. The Court of Appeal concluded that it need not decide whether there are triable issues of fact that would defeat summary judgment. Rather, the court concluded that plaintiff has not pleaded a viable cause of action against either defendant. The court concluded that plaintiff's claims against Foster Farms are barred by federal preemption. In this case, plaintiff's direct causes of action against Foster Farms is based on the premise that its labels' inclusion of the American Humane Certified logo was itself misleading, because the chicken was not treated in a manner that an objectively reasonable consumer would consider humane. The court concluded that these causes of action are barred by the doctrine of federal preemption, based on the express preemption clause of the Poultry and Poultry Products Inspection Act. The court also concluded that the negligent certification claim against American Humane is not viable in the absence of physical injury. View "Leining v. Foster Poultry Farms, Inc." on Justia Law

In 2016, the FRA issued a Notice of Proposed Rulemaking (NPRM) proposing a national minimum requirement of two crew members for trains. In 2019, the FRA issued an order purporting to adopt a nationwide maximum one-person crew rule and to preempt "any state laws concerning that subject matter." Two Unions and three states petitioned for review of the Order under the Administrative Procedure Act (APA).As a preliminary matter, the Ninth Circuit dismissed the Unions' petition because venue was not proper under 28 U.S.C. 2343. The panel explained that the Unions' principal officers were not in the Ninth Circuit. The panel concluded that it had jurisdiction over the States' petitions because they were sufficiently aggrieved to invoke jurisdiction under 28 U.S.C. 2344. On the merits, the panel held that the FRA's Order does not implicitly preempt state safety rules, that the FRA failed to comply with the APA's notice-and-comment provisions in issuing the Order, and that the order is arbitrary and capricious. The panel explained that the Order's basis for its action did not withstand scrutiny, and the FRA's contemporaneous explanation was lacking. In this case, the States met their burden of showing that the issuance of the Order violated the APA. Accordingly, the panel dismissed the petition for review but granted the States' petitions, vacating the Order. View "Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers v. Federal Railroad Administration" on Justia Law

The Ninth Circuit affirmed the district court's grant of summary judgment for defendants in an action brought by plaintiff and his family under the Fair Housing Amendments Act (FHAA). Plaintiff and his family sought to extend their tenancy in defendants' property based on plaintiff's medical condition.The panel agreed with the district court that, under 42 U.S.C. 3604(f)(3)(B), making "accommodations in rules, policies, practices, or services" was not necessary to afford plaintiff and his family "equal opportunity to use and enjoy a dwelling." The panel held that, absent an accommodation, the plaintiff's disability must cause the plaintiffs to lose an equal opportunity to use and enjoy a dwelling. In this case, defendants offered plaintiff and his family, who were on a month-to-month tenancy, terminable at will, a new lease for one year at an increased rent. However, plaintiff and his family turned down the new lease, and never credibly argued that they turned down the lease for any reason related to plaintiff's disability. Upon termination of the lease, plaintiff and his family were in the same position as a family with no disability that had had its lease terminated. The panel explained that it could not find a connection between plaintiff's disability and his request to remain in the home until January 22, 2018. Therefore, defendants were under no obligation to extend the tenancy-termination date. Finally, the panel agreed with the Third and Sixth Circuits and held that there is no standalone liability under the FHAA for a landlord’s failure to engage in an interactive process. View "Howard v. HMK Holdings, LLC" on Justia Law

Kelly, an off-duty Chicago police officer, shot his friend LaPorta in the head during an argument after a night of drinking together. LaPorta’s injuries left him severely, permanently disabled. LaPorta sued the city under 42 U.S.C. 1983, which provides a federal remedy against state actors who deprive others of rights secured by the federal Constitution and laws, arguing that the city had inadequate policies in place to prevent the shooting. He identified several policy shortcomings: the failure to have an “early warning system” to identify officers who were likely to engage in misconduct, the failure to adequately investigate and discipline officers who engage in misconduct, and the perpetuation of a “code of silence” that deters reporting of officers who engage in misconduct.A jury awarded LaPorta $44.7 million in damages. The Seventh Circuit reversed. Whatever viability LaPorta’s claim might have under state tort law, it has no foundation in constitutional law. When Kelly shot LaPorta, he was not acting as a police officer but as a private citizen. LaPorta claimed that he was deprived of his due-process right to bodily integrity but it has long been settled that “a State’s failure to protect an individual against private violence … does not constitute a violation of the Due Process Clause.” View "First Midwest Bank v. City of Chicago" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals dismissing Defendant's appeal and dismissed Defendant's convictions for possession with the intent to deliver more than twenty-six grams of methamphetamine and possession of drug paraphernalia, holding that the initial search of Defendant's house during which law enforcement discovered illegal contraband was unlawful.Defendant pled guilty but specifically reserved a certified question of law pertaining to the legality of the search in this case. The court of criminal appeals dismissed the appeal, determining that the certified question was not dispositive because the evidence would have been admissible notwithstanding the search in question under the inevitable discovery doctrine. The Supreme Court reversed and dismissed Defendant's convictions, holding (1) the inevitable discovery doctrine did not apply in this case; and (2) the State did not carry its burden of proving that either exigent circumstances or voluntary consent justified their warrantless search of Defendant's home. View "State v. Scott" on Justia Law

PBT, on behalf of itself and the owners of the other condominiums, sought an injunction in state court barring the Town from levying a special assessment against their properties. The Eleventh Circuit affirmed the district court's grant of the Town's motion for summary judgment on the owners' substantive due process and equal protection claims. In regard to the substantive due process claim, the court concluded that PBT failed to provide evidence showing that the Town lacked a rational basis in enacting the Resolution as a whole. In regard to the equal protection claim, given the relevant differences between the Comparators and the PB Towers, the court concluded that all that PBT has shown is that the Town Council treated dissimilar properties differently. The court concluded that such treatment does not implicate the Equal Protection Clause. Furthermore, even if they were similar, PBT fails to identify any evidence that an objectively reasonable governmental decisionmaker would consider the similarity it proffers.The court also affirmed the Town's motion to dismiss the owners' state law claims. The court explained that the district court was correct to dismiss the state law takings claims asserted in Count III, but erred in dismissing the state law claim alleging an unconstitutional tax. However, the unconstitutional tax claim was properly before the district court only based on supplemental jurisdiction. Because the federal claims were properly dismissed, the district court may decline to exercise supplemental jurisdiction over this state law claim on remand. Finally, the court concluded that the district court did not abuse its discretion by denying the motion to reconsider. View "PBT Real Estate, LLC v. Town of Palm Beach" on Justia Law