Justia Constitutional Law Opinion Summaries

Petitioner, a death row inmate, appealed the district court's denial of his first federal habeas corpus petition. At issue was whether petitioner was denied the constitutional right to effective assistance of counsel at the penalty phase of his capital trial. Because petitioner filed his federal petition after April 24, 1996, this case was governed by 28 U.S.C. 2254, as amended by the Anti-Terrorism and Effective Death Penalty Act of 1996 (AEDPA). After carefully reviewing the record and having the benefit of oral argument, the court concluded that petitioner had satisfied Strickland v. Washington's demanding standard of deficiency and prejudice, as well as AEDPA's demanding standard, because counsel failed to investigate and to present substantial mitigating evidence. Therefore, the court held that habeas relief was warranted.

Defendant appealed her conviction for aggravated identity theft in violation of 18 U.S.C. 1028A(a)(1). Defendant argued that section 1028A(a)(1) could not be applied to her conduct because that provision did not cover the theft of a person's identity when that person was no longer living. The court held that, viewed together, the text, structure, and purpose of the statute make plain the meaning of section 1028A(a)(1)'s text: the provision criminalizes the use of a real person's identity, regardless of whether that person is currently living. Accordingly, the court affirmed the judgment.

Plaintiff, a teacher at a small Christian school, appealed the district court's grant of summary judgment in favor of the school on her pregnancy discrimination claim, under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., contending that she had established a prima facie case of unlawful discrimination. After admitting to the school's administrator and assistant administrator that she conceived the child before getting married, the school fired her, purportedly because she had sinned by engaging in premarital sex, and, as the administrator put it, "there are consequences for disobeying the word of God." Because the school did not raise any issue or make any argument in its brief about the ministerial exception, the court would not decide whether that exception might apply. The court found that plaintiff's testimony contradicted the administrator's testimony that he had never heard her say she was sorry for what she had done and that he would not have fired her if she had. For that and other reasons, plaintiff had established a genuine issue of material fact about the reason that the school fired her. Accordingly, the court reversed the grant of summary judgment on the pregnancy discrimination claim and remanded for further proceedings.

Petitioner was convicted on three counts of first degree murder and was sentenced to death in Florida's state courts. On collateral review, the district court granted in part petitioner's federal application for writ of habeas corpus, finding that trial counsel was ineffective during the penalty phase of the trial by failing to present substantial mitigating evidence to the jury, and by failing to object to the prosecutor's closing argument to the jury that petitioner preferred a death sentence over life imprisonment. The district court rejected the remainder of the petition, holding, among other things, that trial counsel was not ineffective during the guilt phase of the trial. The court affirmed the district court's denial of habeas relief as to petitioner's guilt-phase ineffectiveness claims; vacated the district court's grant of habeas relief concerning petitioner's penalty-phase ineffectiveness claims; and remanded for the district court to hold an evidentiary hearing on those claims.

Defendant pleaded guilty to drug offenses on the high seas and was sentenced to concurrent imprisonment terms of 120 months, pursuant to the statutory mandatory minimum sentence. Defendant appealed, contending that the district court erred in imposing the sentence. The court affirmed because the offenses for which defendant was convicted did not appear in the 18 U.S.C. 3553(f) list of specified offenses that triggered safety-valve relief.

In this capital case, the State of Florida appealed the district court's order granting habeas relief to petitioner on his claim that the admission of a videotape of his custodial interrogation by law enforcement officers, when he never received any Miranda warnings, yielded prejudicial constitutional error. The court reversed the judgment of the district court, concluding that the district court engaged in its own factfinding process, failed to accept as correct some of the unrebutted factual findings of the Florida Supreme Court that credited significant pieces of the State's case against petitioner; afforded precious little weight to other pieces of evidence that the Florida Supreme Court fairly relied upon; and ignored entirely still other evidence incriminating petitioner. Accordingly, the court concluded that the admission of the videotaped interrogation amounted to harmless error under the "actual prejudice" standard for collateral review set forth by the Supreme Court in Brecht v. Abrahamson.

Plaintiff appealed from a district court order dismissing his 42 U.S.C. 1983 civil rights action against the Attorney General of Florida and the State Attorney for Florida's Eighteenth Judicial Circuit. Plaintiff claimed that the State prevented him from gaining access to physical evidence for purposes of DNA testing, in violation of his procedural due process rights under the Fourteenth Amendment, the Eighth Amendment's prohibition against cruel and unusual punishment, his Sixth Amendment right to confrontation and compulsory process, and his Fourteenth Amendment right of access to the courts. The court affirmed the district court's dismissal of all the claims for failure to state a claim or for lack of subject-matter jurisdiction where the Supreme Court had recently made it clear that there was no freestanding constitutional right to access evidence for DNA testing, and that the federal courts could only upset a state's postconviction DNA access procedures if they were fundamentally inadequate to vindicate substantive rights.

Defendant pleaded guilty to 17 counts of tax-related offenses and was sentenced to 27 months in prison. On appeal, defendant argued that the district court erred by refusing to group all of his counts into a single group pursuant to U.S.S.G. 3D1.2(b) or (d) as "counts involving substantially the same harm." The court agreed and held that all 17 of defendant's counts should have been grouped under section 3D1.2(d) because their offense level was determined largely on the basis of the amount of loss, the underlying offenses were of the same general type, and grouping served section 3D1.2's principal purpose of grouping closely related counts. Accordingly, the court vacated defendant's sentence and remanded for resentencing.

Plaintiffs appealed the district court's grant of Troup's motion for summary judgment as to plaintiffs' sexual harassment claim brought pursuant to Title IX, 20 U.S.C. 1681. The facts of this case stemmed from circumstances surrounding the sexual molestation of a 12-year-old boy by his 45-year-old seventh grade homeroom teacher. The court held that the district court combined Title VII, 42 U.S.C. 2000e et seq., workplace discrimination standards with Title IX teacher-on-student harassment standards when it articulated plaintiff's burden. However, the district court's reliance on the wrong standard did not necessarily mandate that the court must now reverse its decision and remand the case. After considering the factual record and drawing all justifiable inferences in favor of plaintiffs, the court found that the information of which the school principal had knowledge was not enough to create a genuine issue of material fact as to whether he had actual notice sufficient to alert him to the possibility of sexual harassment of the 12-year-old by his teacher. Accordingly, although for different reasons than the district court, the court granted summary judgment.

Petitioner, a Florida prisoner on death row, appealed from the district court's denial of his petition for a writ of habeas corpus, brought pursuant to 28 U.S.C. 2254. Petitioner argued that the trial court erred in sentencing him to death because his sentence was unconstitutionally disproportionate pursuant to the Eighth Amendment and the Supreme Court jurisprudence laid out in Enmund v. Florida and Tison v. Arizona. Petitioner also argued that his trial counsel was ineffective at the guilt phase and at the penalty phase, and that the trial court erred in denying his claim that trial counsel was operating under a conflict of interest by delegating the primary responsibility for litigating petitioner's case to counsel for his co-defendant. The court held that the Florida Supreme Court's resolution of petitioner's case was contrary to or an unreasonable application of clearly established federal law. Therefore, petitioner's habeas petition was denied.