Justia Constitutional Law Opinion Summaries

Defendant was convicted of 130 counts arising, inter alia, from his wire fraud, health care fraud, and unlawful dispensing of controlled substances. Defendant was also convicted of three counts charging a patient's death resulted from the use of controlled substances dispensed by defendant from his health care fraud violation. Defendant appealed his convictions, arguing that the district court gave erroneous instructions to the jury, he received ineffective assistance of trial counsel, and the government's evidence was insufficient to sustain his convictions. The court held that the district court's jury instructions were not erroneous where the district court properly instructed that the 18 U.S.C. 841(b)(1)(C) standard was satisfied upon a finding that, but for the victims ingesting the controlled substances charged in the indictment, the victims would not have died. The court also held that 18 U.S.C. 1347(a) required nothing more than a cause-in-fact connection between defendant's conduct and the death, and that any claimed error in the section 1347(a) charge was harmless. The court rejected defendant's claim that his trial counsel's performance was deficient in that trial counsel failed to make appropriate motions for acquittal at the close of evidence. The court held that, given the overwhelming evidence, the government presented sufficient evidence to sustain all of defendant's convictions and that motions for acquittal, even if made, would have failed. Accordingly, defendant's convictions and sentences were affirmed.

Petitioner, a death row inmate, filed a petition for a writ of habeas corpus under 28 U.S.C. 2254, complaining that he was denied clemency proceedings or alternatively, was denied clemency itself without the benefit of a clemency investigation and clemency counsel. The court held that the district court correctly dismissed petitioner's section 2254 petition where he had no right to clemency that he could enforce through his habeas petition. The court also denied petitioner's request to stay the execution and remand to the district court so that counsel could be appointed and the complaint could be raised under 42 U.S.C. 1983 where petitioner had not shown a significant or substantial likelihood of success on the merits of his clemency claim or claims. Accordingly, the court affirmed the judgment of the district court.

Plaintiffs brought an action against the City of Marietta, Georgia, challenging the validity of its zoning ordinance. The district court granted summary judgment in favor of the city and against plaintiffs on all claims except for one plaintiff's claim (Covenant) that the city's ordinance, as amended in November 2004, facially violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc, by treating religious assemblies less favorably than non-religious assemblies. The court held that claims seeking injunctive relief were moot in light of the passage of the 2008 Ordinance and dismissed those claims for lack of subject matter jurisdiction. The court held that, to the extent that RLUIPA claims sought damages, they failed on the merits because all damages stemmed from Covenant's inability to build a church in the R-2 residential zone and Covenant was not entitled to build a church in that zone. The court further held that the district court did not err in concluding that the 2004 Ordinance facially violated the equal terms provision of RLUIPA and did not err in awarding nominal damages for this claim. The court finally held that the district court did not abuse its discretion in denying Covenant's motion to leave to amend the complaint.

Defendant was convicted and sentenced to death in 1995 for murder. Because defendant was seventeen years old at the time of the murder, the state court eventually set aside his death sentence and resentenced him to life imprisonment. On appeal, defendant contended that his life without parole sentence was an unconstitutional penalty for him because he was not yet eighteen years old at the time he committed the murder. The court held that it owed 28 U.S.C. 2254(d)(1) deference to the state trial and appellate court decisions that defendant's life without parole sentence, and the procedures under which it was imposed, were not unconstitutional in light of the Roper v. Simmons decision.

Defendant pleaded guilty to possession with intent to distribute 50 grams or more of cocaine base and was sentenced to 127 months in prison. Defendant appealed his sentence and contended that an intervening decision showed that the district court erred by failing to apply the Fair Sentencing Act of 2010 (FSA) in determining his sentences. The court held that FSA claims, like any other type of sentence claim, could be waived by a knowing and voluntary appeal waiver. Therefore, the court affirmed the sentence where defendant waived his right to appeal his sentence.

Plaintiff, a death row prisoner who was scheduled to be executed by the State of Florida, filed a complaint under 42 U.S.C. 1983 and a motion for TRO and preliminary injunction and to stay his execution, alleging that Florida's use of an altered lethal injection protocol violated the Eighth Amendment. Plaintiff subsequently appealed the district court's denial of his motion and plaintiff sought a stay of execution from this court so that he could obtain a merits ruling on his complaint. The court held that plaintiff had not demonstrated that he had a substantial likelihood of success on the merits of his Eighth Amendment claim and therefore, denied plaintiff's motion for stay of execution.

Plaintiff, a Georgia state prisoner proceeding pro se, appealed the district court's sua sponte dismissal, under 42 U.S.C. 1997e(a) and 28 U.S.C. 1915A, of his 42 U.S.C. 1983 civil rights action. On appeal, defendant argued that the district court erred in dismissing his claims. The court held, and the state conceded, that the district court erred in dismissing without prejudice defendant's dental treatment claim on the basis that it was "clear from the face of the complaint" that defendant had not exhausted his administrative remedies with regard to this claim. The court held, however, that there was no merit in defendant's remaining claims. Accordingly, the court affirmed in part, vacated in part, and remanded in part.

The United States appealed an award of attorney's fees and costs under the Hyde Amendment, Pub. L. No. 105-119, section 617, 111 Stat. 2440, 2519, and two attorneys, Sean Cronin and Andrea Hoffman, appeal public reprimands entered against them based on their work as Assistant United States Attorneys in an underlying criminal action marked by hard adversarial tactics. The court held that the district court abused its discretion when it imposed sanctions against the United States for a prosecution that was objectively reasonable, and the district court violated the constitutional right to due process of the two lead prosecutors, when it denied them notice of any charges of misconduct and an opportunity to be heard. Therefore, the court vacated the award of attorney's fees and costs against the United States and the public reprimand of Cronin and Hoffman, but the court denied the request of Cronin and Hoffman that the court reassign the case to a different district judge at this stage.

Petitioner appealed the district court's denial of his petition for a writ of habeas corpus filed pursuant to 28 U.S.C. 2241. Petitioner was subject to the 1976 Parole Commission and Reorganization Act, 18 U.S.C. 4101-4218, because he was incarcerated for an offense he committed prior to the effective date of the Federal Sentencing Guidelines, specifically, petitioner was serving a life sentence for the 1976 murder of a U.S. Park Ranger. At issue was whether the U.S. Parole Commission engaged in "unauthorized action" during petitioner's mandatory parole proceedings. The court held that the Commission was engaged in such unlawful action, which impermissibly tainted the Commission's June 14, 2005 decision reopening petitioner's mandatory parole proceedings.

Appellant appealed the district court's judgment denying it sovereign immunity protection as an arm of the state of Alabama. Appellee contended that appellant was sufficiently independent from the state of Alabama, that it was not entitled to Eleventh Amendment immunity, and that her claim under the Fair Labor Standards Act, 29 U.S.C. 201 et seq., should be allowed to continue. At issue was whether appellant was an arm of the state. The court held that at this time, appellant was not entitled to sovereign immunity protection as an arm of the state of Alabama where the state court found that an entity was not an arm of the state. Accordingly, the court affirmed the judgment of the district court.