Justia Constitutional Law Opinion Summaries

Plaintiff, an African -American, brought this action against UPSF, his former employer, alleging that he had been subjected to a racially hostile work environment in violation of 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2. The district court entered summary judgment in favor of UPSF and plaintiff timely appealed. The court concluded that a reasonable trier of fact could conclude that the events alleged by plaintiff created an objectively hostile work environment and therefore, the court vacated the judgment and remanded for further proceedings.

Petitioner appealed the district court's dismissal of his 28 U.S.C. 2254 petition for failure to meet the "in custody" requirement. The district court found that because petitioner had completely served the sentence imposed by the state court, he was no longer "in custody pursuant to the judgment of a State court" as required by section 2254(a). The court affirmed the district court's dismissal because petitioner served his state sentence and was presently in custody of a different sovereign.

The Chapter 7 trustee for the bankruptcy estate of Stacey Williams appealed the district court's grant of summary judgment to Gate Gourmet on Williams' claim of pregnancy discrimination, race discrimination, retaliation, and state law negligence. The court held that the district court improperly granted summary judgment on Williams' Title VII, 42 U.S.C. 2000e et seq., claim for pregnancy discrimination because Williams had presented enough circumstantial evidence to allow a jury to reasonably infer that her supervisor's action in terminating her because of her pregnancy and his inaction in not attempting to find her a light-duty job were a violation of Title VII. The district court properly granted summary judgment to Gate Gourmet on Williams' Title VII and 42 U.S.C. 1981 race discrimination claims because she had not shown a genuine issue of material fact about whether Gate Gourmet intentionally discriminated against her based on her race. Summary judgment was improperly granted against Williams' Title VII and section 1981 retaliation claims because there was a reasonable inference that the statutorily protected filing of and refusal to settle the EEOC charge caused Gate Gourmet to deny Williams a light-duty position, which was a materially adverse action. The court affirmed in part, reversed in part, vacated in part, and remanded.

In this capital case, petitioner was convicted of one count of first-degree murder for the 1976 death of a sixteen-year-old victim and two counts of attempted first-degree murder for the shootings of two other victims. A federal district court subsequently denied petitioner's petition for a writ of habeas corpus, which included claims that: (1) the state trial court's admission of testimony of an undisclosed rebuttal witness was unconstitutional; (2) petitioner's trial counsel rendered ineffective assistance; and (3) the State's use of peremptory challenges to exclude all jurors who expressed reservations about the death penalty was unconstitutional. After thorough review, the court concluded that petitioner was not entitled to relief on any of these claims. Accordingly, the court affirmed the district court's judgment and denied the petition.

This appeal and cross-appeal arose from a jury verdict and award of damages and injunctive relief in favor of plaintiffs, Doctors Gowski and Zachariah, in their discrimination, retaliation, and hostile work environment suit against the Secretary of the Department of Veterans Affairs (VA). At issue was whether this circuit recognized a retaliatory hostile work environment claim and, if so, whether the evidence in this case was sufficient to support the jury's verdict and damages award. The court concluded that a retaliatory hostile work environment was a viable claim and, after a thorough review of the record and with the benefit of oral argument, the court affirmed the district court's denial of the motion for judgment as a matter of law and for a new trial, the remittur, the vacatur of the lost-wages award, and the award of attorneys' fees. The court also affirmed in part the grant of injunctive relief, but remanded in part the injunctive award with instructions for the district court to strike the award as it pertained to the removal of the doctors' disciplinary files and the prevention of their use in any further disciplinary action; the order that the doctors be appointed to additional hospital committees; the order that Dr. Gowski be placed back on the rotation for duty assignments and be permitted to obtain the necessary credentials and privileges to do so; and the order that Dr. Zachariah be permitted to continue her research.

This case involved the competitive bidding for an airport advertising concession. After the completion of the bid process, plaintiff - the second-place finisher - brought this action pursuant to 42 U.S.C. 1983, alleging a conspiracy to violate plaintiff's equal protection rights during the bid process. The court concluded that plaintiff's conspiracy claim failed against defendants because the underlying proposed equal protection claim failed, lacking the sufficient identifiable group required. Therefore, the court concluded that the facts and inferences in this case pointed overwhelmingly in favor of defendants. Accordingly, the court vacated the district court's post-verdict order denying judgment as a matter of law and remanded with instructions to grant judgment as a matter of law to defendants.

Defendant appealed following his conviction for alien smuggling for commercial gain. Defendant argued that the district court erred by: (1) denying his motion to dismiss the indictment based on vindictive prosecution; (2) failing to grant a judgment of acquittal based on insufficiency of the evidence; (3) granting the government's motion in limine precluding defendant from discussing the events of his prior trial beyond an excerpt of his own sworn testimony; and (4) denying defendant's motion in limine seeking to introduce portions of the prosecutor's closing argument from defendant's prior trial as an admission of a party opponent under Fed. R. Evid. 801(d)(2). After thorough review of defendant's claims, the court affirmed the judgment.

Defendant appealed from his sentence of illegal reentry of a deported alien. The district court enhanced his base offense level by sixteen levels because he had previously been convicted of a "crime of violence" under U.S.S.G. 2L1.2(b)(1)(A), and reduced it by three levels under U.S.S.G. 3E1.1 for acceptance of responsibility. The court held that the distinct definition of "crime of violence" provided in the commentary to section 2L1.2 remained "authoritative" and the district court did not err by relying on the commentary in imposing the sixteen-level enhancement. Accordingly, the court affirmed the judgment.

Petitioner filed an application pursuant to 28 U.S.C. 2255(h) and 2244(b)(3)(A), seeking an order authorizing the district court to consider a second or successive motion to vacate, set aside, or correct his federal sentence. The court held that, because petitioner failed to make a prima facie showing of the existence of either grounds set forth in section 2255(h), his application for leave to file a second or successive motion was denied.

Defendant pleaded guilty to possession with intent to distribute oxycodone and to being a felon in possession of a firearm. At issue was whether a Florida conviction for false imprisonment was a "violent felony" under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). The court concluded that Florida false imprisonment was not a strict liability, negligence, or reckless crime. It required an intent to confine, abduct, imprison, or restrain another person without lawful authority and against her or his will. The Begay v. United States inquiry into whether the crime was purposeful, violent, and aggressive therefore did not, under Sykes v. United States and United States v. Chitwood, apply. Accordingly, the court affirmed the judgment.