Justia Constitutional Law Opinion Summaries

Relator filed a qui tam action under the False Claims Act (FCA), 31 U.S.C. 3729-3733, against the District, alleging that the District violated the FCA by fraudulently claiming FEMA reimbursements for ineligible canal repairs. The court held that, as an arm of the State of Florida, the District was not a "person" that could be subjected to suit by a qui tam relator under the FCA. Accordingly, the court affirmed the district court's dismissal of relator's claims. View "Lesinski v. South Florida Water Mgmt." on Justia Law

Plaintiff filed suit alleging that a corrections officer at the county jail sexually assaulted her. Officers other than the accused moved for dismissal on the basis of qualified immunity. The district court denied the motion. The court concluded that, in determining whether plaintiff alleged a constitutional violation, the district court made two related errors: it applied an incorrect legal standard and it allowed plaintiff to satisfy the standard it applied with conclusory allegations. Accordingly, the court held that plaintiff had failed to plead a constitutional violation and that the officers were therefore entitled to qualified immunity. View "Franklin v. Curry, et al." on Justia Law

Plaintiffs, daughters of the late Kenneth Weinberg, appealed the district court's grant of summary judgment to county jail officers. Kenneth, a pretrial detainee at the jail for twenty months, commenced this civil rights suit under the Due Process Clause of the Fourteenth Amendment, claiming deliberate indifference to his basic medical needs because the officers refused to provide him with batteries for his hearing aids, rendering the aids worthless and leaving him unable to hear. Kenneth also filed suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and a First Amendment retaliation claim against the officers for the same conduct. The court concluded that Kenneth stated a viable constitutional claim but that state law did not provide the officers with "fair warning" that their alleged conduct was unlawful. Accordingly, the officers were entitled to qualified immunity and the court affirmed the district court's grant of summary judgment in favor of the officers. View "Weinberg Gilmore, et al. v. Hodges, et al." on Justia Law

Plaintiffs, on behalf of their daughter, filed suit challenging the district's implementation of a new individualized education program (IEP) for their daughter under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Determining that the daughter's case was not moot, the court concluded that the court need not decide whether the various notice requirements were satisfied because whatever notice deficiencies there could have been in this case, they did not warrant relief; there was no error in requiring the parents to present a complaint and demand a due process hearing because they disagreed with the IEP team's decision; the district court correctly stated the Loren F. ex. rel. Fisher v. Atlanta Independent School System standard, fully reviewed the administrative record, and independently analyzed each of the parents' claims; the district court did not abuse its discretion when it issued the parents' proposed order and then decided the case on summary judgment; and the court held that 42 U.S.C. 1983 actions for denial of rights conferred by the IDEA were barred because the IDEA's comprehensive enforcement scheme provided the sole remedy for statutory violations and, therefore, the district court did not err in dismissing the parents' section 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "K.A. v. Fulton County Sch. Dist." on Justia Law

Louis Vuitton filed a federal trademark infringement suit against defendant for operating websites that were selling counterfeit Louis Vuitton bags. On appeal, defendant challenged the district court's denial of his motion to vacate a default judgment entered against him. The court concluded that, under the unrebutted allegations and testimony, the district court in Florida did not violate the Due Process Clause by exercising personal jurisdiction over defendant for Louis Vuitton's trademark infringement claims. The district court did not err in denying defendant's motion to vacate the default judgment because the statutory and federal constitutional personal jurisdiction requirements were satisfied. Accordingly, the court affirmed the judgment of the district court. View "Louis Vuitton Malletier, S.A. v. Mosseri" on Justia Law

Defendant appealed her conviction for knowingly transmitting a threatening communication under 18 U.S.C. 875(c). Defendant sent an anonymous email to a local radio show host threatening, inter alia, the safety of local schools. The court held that Virginia v. Black did not require a subjective-intent analysis for all true threats. Therefore, when the Government shows that a reasonable person would perceive the threat as real, a true threat may be punished and any concern about the risk of unduly chilling protected speech has been answered. The court also rejected defendant's overbreadth claim. Because true threats are unprotected speech, and because the court's reading of section 875(c) limited that statute to true threats, defendant had not demonstrated a realistic danger that the statute would significantly compromise recognized First Amendment protections. Accordingly, the court affirmed the district court's conviction and restitution order. View "United States v. Martinez" on Justia Law

Plaintiff filed suit against Marod to compel it to bring one of its stores into compliance with Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. 12181-12189. The district court dismissed the claim, concluding that plaintiff lacked standing. The court concluded that plaintiff had standing to seek injunctive relief against defendant where plaintiff has been to the store in the past, he wants to return, and his frequent trips directly past the store render it likely that he would do so were it not for the alleged ADA violations. Accordingly, the court reversed the district court's dismissal of plaintiff's claim. View "Houston v. Marod Supermarkets, Inc." on Justia Law

The court sua sponte reconsidered its original opinion in this matter and substituted this opinion for its original. This appeal by R.J. Reynolds of money judgments in favor of the survivors of two smokers required the court to decide whether a decision of the Supreme Court of Florida in an earlier class action was entitled to full faith and credit in federal court. Because R.J. Reynolds had a full and fair opportunity to be heard in the Florida class action and the application of res judicata under Florida law did not cause an arbitrary deprivation of property, the court affirmed the judgments against R.J. Reynolds and in favor of the survivors of the smokers. View "Walker v. R.J. Reynolds Tobacco Co." on Justia Law

Plaintiff filed suit against her employer for gender discrimination, racial discrimination, and national origin discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq., as well as hostile work environment, unlawful retaliation claims, and state law claims. On appeal, plaintiff challenged the district court's grant of summary judgment in the employer's favor. The court concluded that plaintiff has made out a prima facie case of employment discrimination, but it remained unclear as to whether she created a dispute of material fact regarding whether the reason the employer offered for hiring another employee over her was a pretext for discriminatory animus. Accordingly, the court vacated the district court's grant of summary judgment in favor of the employer regarding plaintiff's employment discrimination claim, remanding for further proceedings. The court affirmed in all other respects. View "Kidd v. Mando American Corp." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the City and others after he was fired from the police department for violating department policies. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of defendants. The court concluded that the district court correctly concluded that plaintiff failed to establish that any of the personnel, internal affairs, or disciplinary decisions about which he complained was made by a final policy maker for the City such that municipal liability attached; plaintiff's First Amendment claims failed because he could not establish that his speech played a substantial part in the police department's decision to conduct internal affairs investigations or terminate him; and plaintiff's false arrest, imprisonment, and malicious prosecution claims also failed because he has not presented any evidence that he was arrested without probable cause and the evidence could not be read to establish that there was a causal connection between either of the individual defendants' actions and plaintiff's arrest, imprisonment, and prosecution. Accordingly, the court affirmed the grant of summary judgment to all defendants. View "Carter, Jr. v. City of Melbourne, FL, et al." on Justia Law