Justia Constitutional Law Opinion Summaries

The city filed a complaint in admiralty against defendant, a vessel, claiming that defendant committed the maritime tort of trespass because it remained at the city marina after the city explicitly revoked its consent, and seeking to foreclose its maritime lien for necessaries (unpaid dockage provided to defendant by the city). Claimant, owner of the vessel, appealed from the district court's entry of an order of summary judgment and an order of final judgment for the city in an in rem proceeding against defendant. The court held that the district court did not err in concluding that it had federal admiralty jurisdiction over defendant where defendant was a "vessel" for purposes of admiralty jurisdiction; the district court's factual findings regarding the amount claimant owed under the city's maritime lien for necessaries were not clearly erroneous; the district court did not err in granting summary judgment to the city on claimant's affirmative defense of retaliation; the district court correctly concluded that the city was not estopped from bringing its action in admiralty against defendant; and the district court did not abuse its discretion in declining to apply collateral estoppel because the issues at stake were significantly different from those in dispute in the state court proceeding. Accordingly, the district court's orders were affirmed.

Defendant was indicted in October 2006 of conspiring to "possess with the intent to distribute, and to distribute, 50 grams or more of cocaine base (crack) and 5 kilograms or more of cocaine hydrochloride (powder)." In September 2007, defendant pleaded guilty to the lesser-included offense of conspiracy to distribute an unspecified quantity of both identified drugs. Defendant subsequently appealed substantive and procedural aspects of his 151 months imprisonment. The court held that because there was no basis to disturb the ruling, or any of the other decisions defendant challenged, the court affirmed the judgment of the district court.

This appeal stemmed from a violent drug conspiracy in South Florida that involved a number of criminals. The four whose joint trial led to this appeal were Daniel "D.V." Varela, Liana "The Negra" Lopez, Ricardo "Rick" Sanchez, and Daniel "Homer" Troya. During their crime wave, Troya and Sanchez carjacked a fellow drug dealer and shot him to death, as well as his wife and their two young children. Lopez and Varela, on appeal, raised several issues, the primary one being that they should not have been jointly tried with Troya and Sanchez. The court held that the district court did not abuse its discretion by denying the motions for severance and proceeding with a joint trial of all four conspirators who resided in the "Thug Mansion." The court also held that the district court did not abuse its discretion in denying Varela's motion to sever the felon-in-possession charges against him from the other charges; by requiring that all four of the defendants agree on the exercise of any peremptory challenges; in denying Varela's motion to suppress the results of the October 25 search of the "Thug Mansion;" and by allowing Varela's former cocaine customers to testify about their dealings with him. The court further held that the mandatory life sentence of life imprisonment that 21 U.S.C. 841(b)(1)(A) provided did not violate the Eighth Amendment's Cruel and Unusual Punishment Clause in light of United States v. Willis. Accordingly, the judgment of the district court was affirmed.

Count One of the multi-count indictment in this case charged Robert and Patrick Singletary, and others, with conspiring between 1997 and September 16, 2004, in violation of 18 U.S.C. 371, to commit three offenses: (1) to defraud a federally insured bank, in violation of 18 U.S.C. 1344; (2) to make false representations with respect to material facts to the United States Department of Housing and Urban Development (HUD), in violation of 18 U.S.C. 1001; and (3) to defraud purchasers of residential property and mortgage lenders, in violation of 18 U.S.C. 1343. The Singletarys eventually pled guilty to Count One to the extent that it alleged a conspiracy to commit the section 1343 offense in addition to the section 1001 offense. At issue was whether the district court abused its discretion in ordering restitution in the sum of $1 million. The court held that the district court failed to determine by a preponderance of the evidence which of the 56 mortgages the loan officers handled was obtained through a false "gift" letter, a false "credit explanation" letter, or a false employment verification form; and where fraud was found, to determine the extent of the actual loss HUD could have incurred due to the mortgage's foreclosure. Accordingly, the court vacated the restitution provisions and remanded for further proceedings.

Plaintiffs brought this action challenging the constitutionality of the Patient Protection and Affordable Care Act, Pub. L. 111-148, 124 Stat. 119, amended by Health Care and Education Reconciliation Act of 2010 (HCERA), Pub. L. No. 111-152, 124 Stat. 1029 (Act). The government subsequently appealed the district court's ruling that the individual mandate was unconstitutional and the district court's severability holding. The state plaintiffs cross-appealed the district court's ruling on their Medicaid expansion claim. The court held that the Act's Medicaid expansion was constitutional. The court also held that the individual mandate was enacted as a regulatory penalty, not a revenue-raising tax, and could not be sustained as an exercise of Congress's power under the Taxing and Spending Clause; the individual mandate exceeded Congress's enumerated commerce power and was unconstitutional; and the individual mandate, however, could be severed from the remainder of the Act's myriad of reforms. Accordingly, the court affirmed in part and reversed in part the judgment of the district court.

Plaintiff, owner and operator of a flat-rate ground transportation service, filed a lawsuit seeking declaratory and injunctive relief, claiming that the Hillsborough County Public Transportation Commission's (Commission) regulations required him to obtain certificates and permits for his vehicles were preempted by 49 U.S.C. 14501, also known as the Transportation Equity Act for the 21st Century. Specifically, plaintiff contended that section 14501(a)(1)(C) preempted the Commission's regulation regarding his 15-passenger vehicle and section 14501(c)(1) preempted the Commission's regulation regarding his 7-passenger minivan. The court affirmed the district court's decision rejecting plaintiff's first argument and adopted that court's reasoning. The court also held that, because plaintiff transported property only as an ancillary service to the transportation of passengers he was not a "[m]otor carrier of property" under section 14501(c). Consequently, it followed that the provision and its subparts did not preempt the Commission's luxury service transportation rule. Accordingly, the district court correctly granted summary judgment to the Commission.

In this reverse discrimination case under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981, plaintiff, a white male, claimed that his former employer discriminated against him on account of his race in terminating his employment. At issue was whether the district court misapplied the summary judgment standard to the evidence presented. Based on the totality of the circumstances, the court held that the record contained sufficient circumstantial evidence from which a jury could infer that the employer displayed a racially discriminatory animus toward plaintiff when it fired him in May 2005. Consequently, plaintiff presented a case sufficient to withstand the employer's motion for summary judgment. Therefore, the judgment of the district court was vacated and remanded for further proceedings.

Martin J. Bradley III and his father, Martin J. Bradley, Jr. (collectively, the Bradleys), owned Bio-Med Plus, Inc. (Bio-Med), a Miami-based pharmaceutical wholesaler that purchased and sold blood-derivatives. This case stemmed from multiple schemes to defraud the Florida and California Medicaid programs by causing them to pay for blood-derivative medications more than once. The Government chose to prosecute the schemes and a grand jury indicted eight individuals, including Albert L. Tellechea, and two companies, Bio-Med, and Interland Associates, Inc. The Bradleys, Bio-Med, and Tellechea subsequently appealed their convictions and raised several issues on appeal. The court affirmed the Bradleys', Bio-Med's, and Tellechea's convictions, and Bradley III's and Bio-Med's sentences. The court vacated Bradley, Jr.'s sentences on Counts I and 54 and Tellechea's sentence on Count 3, and remanded those counts for resentencing. The court reversed the district court's October 4, 2006 order appointing the receiver and monitor, and its supplemental receivership order of May 17, 2007. The court finally held that, as soon as circumstances allowed, the receivership should be brought to an immediate close.

Petitioner appealed the denial of his 28 U.S.C. 2254 habeas corpus petition challenging his death sentence after he was convicted of murdering two people. At issue was whether defendant was denied his Sixth, Eighth, and Fourteenth Amendment rights to effective assistance of counsel when the trial court denied his requests to remove his lawyer and his lawyer's requests to withdraw and when his lawyer failed to investigate and to present mitigating evidence at resentencing in addition to that which the lawyer presented at the original sentencing. The court held that defendant was not denied effective assistance of counsel and in applying the deferential review standard mandated by the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2254(d)(1), (d)(2), the Florida Supreme Court's ruling was not contrary to, and did not involve an unreasonable application of, clearly established federal law and was not based on an unreasonable determination of the facts. Accordingly, the court affirmed the denial of habeas corpus relief.

This case stemmed from defendant's spree of murder and mayhem that covered three counties of rural Georgia. Defendant was convicted of malice murder, armed robbery, and aggravated assault. Defendant was sentenced to death and appealed the denial of his petition for a writ of habeas corpus. At issue was whether the prosecution's exercise of six peremptory challenges against six black members of the jury venire on the basis of race was in violation of the Fourteenth Amendment. Also at issue was whether certain arguments made by the prosecutor amounted to misconduct that deprived defendant of a fair trial. The court held that the adjudication of defendant's Batson claims and prosecutorial misconduct claims by the Supreme Court of Georgia was not contrary to, or an unreasonable application of, clearly established federal law, and was not an unreasonable determination of the facts. Therefore, the court held that, after careful review of the record, defendant's claims lacked merit. The court further held that three remaining claims raised by defendant also failed. Accordingly, the court affirmed the conviction and sentence.