Justia Constitutional Law Opinion Summaries

Plaintiffs in this case were individuals who were in committed same-sex relationships. Plaintiffs sued the State, contending that there was a statutory structure in Montana law that prohibited them from enjoying significant relationships and family protections and obligations provided to similarly-situated different-sex couples who marry. Plaintiffs expressly did not challenge Montana law's restriction of marriage to heterosexual couples and did not seek the opportunity to marry. Instead, Plaintiffs sought a declaration that the State's failure to provide them access to the statutory scheme available to different-sex couples denied them the rights guaranteed by Mont. Const. art II. The district court granted the State's motion to dismiss, noting that Plaintiffs did not seek the declaration of the unconstitutionality of a specific statute but rather a direction to the legislature to enact a statutory arrangement, which was unprecedented in Montana law. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court did not err in finding Plaintiffs' requested relief exceeded the bounds of a justiciable controversy; but (2) Plaintiffs should be afforded the opportunity to amend their complaint. View "Donaldson v. State" on Justia Law

After a jury trial, Defendant was convicted of the first degree murder of Raymond Shield. In addition, the jury (1) found true the special circumstance allegation that Defendant murdered Shield while in the commission of an attempted robbery, (2) found Defendant guilty of second degree attempted robbery of Shield, and (3) found Defendant guilty of three other second degree robberies of four other victims. Defendant was sentenced to death for the murder and prison terms for the robberies. The Supreme Court affirmed the trial court's judgment in its entirety, holding that the trial court did not commit reversible error in its rulings regarding jury selection, regarding the guilt phase of the trial, and regarding the penalty phase of the trial. View "People v. Watkins" on Justia Law

Plaintiff, a wheelchair user, sued a grocery store owner, contending that a four-inch step located at the entry of the market was an architectural barrier that prevented him and other wheelchair-bound individuals from wheeling into the store and asserting four state and federal law disability access claims. The trial court granted summary judgment for Defendant. The trial court concluded fees for a prevailing defendant under Cal. Civ. Code 55 were mandatory and awarded Defendant $118,458. The court of appeal affirmed. The Supreme Court affirmed, holding that appellate court did not err in determining that Defendant, as the prevailing party, was entitled to costs and, under section 55, to appellate attorney fees as well, as (1) the plain language of section 55 makes an award of fees to any prevailing party mandatory; and (2) the federal Americans with Disabilities Act does not preempt this part of the state's attorney fee scheme for disability access suits. View "Jankey v. Lee" on Justia Law

These appeals arose from allegations that the City of Durham and its officials mishandled false rape charges made against members of the 2005-2006 Duke University lacrosse team. The City and its officials asserted various immunities from suit and on that basis moved to dismiss, or for summary judgment, as to all claims alleged against them. The district court granted those motions in part and denied them in part. The City and its officials appealed. The court reversed the district court's denial of all defendants' motions to dismiss the federal claims alleged against them; reversed the denial of the City's motion for summary judgment as to the state common-law claims alleged against it; affirmed the denial of Officer Gottlieb and Himan's motions to dismiss the state common-law malicious prosecution claims alleged against them; reversed the denial of the officers' motions to dismiss all other state common-law claims; dismissed for lack of appellate jurisdiction the City's appeal of the state constitutional claims alleged against it; and remanded the cases for further proceedings. View "Evans v. Chalmers" on Justia Law

In 2008, Dixon, an African-American woman and then-interim Associate Vice President for Human Resources at the University of Toledo, wrote an op-ed column in the Toledo Free Press rebuking comparisons drawn between the civil-rights and gay-rights movements. Shortly thereafter, Dixon was fired. Claiming violations of her First and Fourteenth Amendment rights, Dixon filed a 42 U.S.C. 1983. The district court granted summary judgment to the defendants on all claims. The Sixth Circuit affirmed. The speech of a high-level Human Resources official who writes publicly against the very policies that her government employer charges her with creating, promoting, and enforcing is not protected speech. View "Dixon v. Univ. of Toledo" on Justia Law

On December 7, 2009, Burd pleaded guilty in Illinois state court to attempted burglary. He had 30 days to withdraw the plea. For the first 29 days of this period, he was held at prison facilities that had no library resources. On the thirtieth day, he was transferred and immediately asked to use the library. Officials told him the library was closed. Burd missed the filing deadline, but continued to seek access to the law library. He filled out request slips, but each time he was denied access because the library was closed. When he explained to Sessler, the prison educational administrator, that he wanted to research withdrawing his plea or an appeal of his sentence, she told him that any such action would be untimely and denied him access to the library. Burd also requested that a fellow inmate be permitted to assist him with his motion. He never received a response. Burd did not seek to set aside his conviction through federal or state habeas corpus before filing under 42 U.S.C. 1983. The Seventh Circuit affirmed rejection of his request for damages as for failure to seek collateral relief.View "Burd v. Sessler" on Justia Law

A group of Freedmen, former Cherokee slaves and their descendants, sued in district court claiming that the Cherokee Nation had violated the 1866 Treaty that guaranteed the Freedmen all the rights of native Cherokees. To avoid the sovereign immunity bar, the Freedmen sued not only the Cherokee Nation itself but also the relevant executive official, the Principal Chief, in his official capacity. Applying the precedents that permitted suits against government officials in their official capacities, the court concluded that this suit could proceed against the Principal Chief in his official capacity, without the Cherokee Nation itself as a party. The Cherokee Nation and the Principal Chief in his official capacity were one and the same in the Ex Parte Young suit for declaratory and injunctive relief. As a result, the Principal Chief could adequately represent the Cherokee Nation in this suit, meaning that the Cherokee Nation itself was not a required party for purposes of Federal Rule of Civil Procedure 19. Accordingly, the court reversed and remanded for further proceedings. View "Vann, et al v. DOI, et al" on Justia Law

The Supreme Court addressed cross-appeals in this opinion, arising from a capital matter from an order of the Court of Common Pleas of Philadelphia County. The lower court granted partial relief under the Post Conviction Relief Act (PCRA), which the Commonwealth appealed insofar as it granted relief on Appellee Jose DeJesus's claim that he was ineligible for the death penalty under "Atkins v. Virginia," (536 U.S. 304 (2002)), because he was mentally retarded. Appellee cross-appealed the PCRA court's concurrent denial of his various other PCRA claims. At trial, before the court issued a decision on Appellee's "Atkins" claim, the Commonwealth filed a motion to reopen the record, asserting that it had recently received information from prison officials that she substantial doubt on appellee's claims of mental retardation. The PCRA Court denied the Commonwealth's motion, offering no further explanation or discussion for the denial. The PCRA court concluded that appellee had met his burden to prove limited intellectual functioning. In the court's view, the Commonwealth's evidence and argument that appellee malingered on his post-Atkins tests, while "compelling," did not "carry the day." The PCRA court also addressed the merits of the claims raised by appellee in his cross-appeal, rejecting them all. The Supreme Court concluded the PCRA Court abused its discretion in not entertaining the Commonwealth's new evidence. "The Commonwealth's proffer specified that this evidence was relevant to the intellectual and adaptive function elements of Atkins because it showed appellee's ability, not only to function within prison, but to use his wits and skills to 'beat the system' in a manner that required forethought, direction and coordination of others." The Supreme Court vacated the PCRA court's decision and accompanying order which found appellee mentally retarded and vacated his death sentences, but otherwise denied relief. This matter was remanded for further Atkins proceedings. View "Pennsylvania v. DeJesus" on Justia Law

Appellant brought suit against officials of the Administrative Office, solely in their official capacities, alleging that they rejected her job application in violation of her constitutional rights. The district court dismissed appellant's complaint, concluding that it lacked jurisdiction because the Administrative Office had sovereign immunity from suit. The court reversed the judgment and held that appellant's claim fell within the Larson-Dugan exception to the general rule of sovereign immunity. Since the district court did not address appellees' alternative jurisdiction arguments, the court left all of these arguments for consideration on remand. Accordingly, the court reversed and remanded for further proceedings. View "Pollack v. Duff, et al" on Justia Law

After a jury trial, Defendant was convicted of three counts of first-degree child molestation and three counts of second-degree child molestation. Defendant appealed, arguing that the trial justice's denial of his motion for a new trial was clearly erroneous because the jury's verdict was against the weight of the evidence and failed to do substantial justice. Specifically, Defendant argued that the testimony of the complaining witness lacked credibility. The Supreme Court affirmed, holding (1) the trial justice performed an exhaustive review of the testimony presented at trial and thoughtfully evaluated the evidence and credibility of the witnesses; and (2) the trial justice's findings and conclusions in denying Defendant's motion for a new trial were well within his discretion. View "State v. LaPierre" on Justia Law