Justia Constitutional Law Opinion Summaries

Plaintiff, a civil detainee at the Florida Civil Commitment Center (FCCC), was involuntarily committed pursuant to Fla. Stat. 394.910 et seq. Plaintiff filed suit under 42 U.S.C. 1983, alleging that defendant, the facility director at the center, violated his expressive freedoms under the First and Fourteenth Amendments by promulgating a policy that limited all residents of the center from copying plaintiff's newsletter. In November 2010, after litigation had begun but before the district court had entered summary judgment for defendant, defendant adopted a new, different, and stricter policy. The court vacated and remanded, concluding that the district court should consider the constitutionality of the November 2010 policy along with the earlier policy in order to avoid piecemeal adjudication of the two policies. View "Pesci v. Budz" on Justia Law

R.J. Reynolds appealed money judgments in favor of the survivors of two smokers. At issue was whether a decision of the Supreme Court of Florida in an earlier class action was entitled to full faith and credit in federal court. The court affirmed the judgments in favor of the survivors 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. View "Walker, et al. v. R.J. Reynolds Tobacco Co." on Justia Law

This case arose when three former employees of ASU alleged that they were subjected to a hostile work environment and retaliation during their employment. ASU appealed the district court's judgment. The court concluded that the district court did not err in denying ASU's motion to sever where the district court had broad discretion to deny the severance in the interest of judicial economy; the court did not have jurisdiction to hear ASU's appeal of the district court's denial of its Rule 50(b) and 59(b) motion where ASU had not filed a notice of appeal with the district court clerk; and the district court did not abuse its discretion in awarding front pay. Accordingly, the court affirmed in part and dismissed in part. View "Weatherly, et al. v. Alabama State University" on Justia Law

Temple B'Nai Zion brought statutory and constitutional challenges to its designation as a historic landmark by a municipality. At issue was whether Temple's challenges were ripe for adjudication. The court concluded that the Temple's complaint alleged a dispute sufficiently concrete to render the instant controversy ripe and justiciable without further delay. Accordingly, the court vacated and remanded the judgment of the district court. View "Temple B'Nai Zion, Inc. v. City of Sunny Isles Beach, FL, et al." on Justia Law

This case concerned the constitutional validity of two statutes, O.C.G.A. 15-21A-6(c), the statute requiring a person to pay $50 for the appointment of counsel in a criminal case, and O.C.G.A. 42-8-100(g), the statute permitting a Georgia county to contract with private entities for the provision of probation services. The court concluded that plaintiff lacked standing to challenge the two statutes where plaintiff failed to establish, inter alia, the likelihood that he would once again be brought before the state court to answer a criminal charge, and plaintiff failed to demonstrate a sufficient likelihood of being convicted in state court and being placed on probation. Accordingly, the court vacated the district court's decision dismissing plaintiff's case as moot. View "McGee v. Solicitor General of Richmond County, et al." on Justia Law

After the Estate of Juanita Amelia Jackson could not collect on a judgment because assets were allegedly fraudulently transferred to GE and Rubin Schron, it initiated a supplementary proceeding in a Florida state court under Florida Statutes section 56.29(6). Section 56.29(6) allowed a court to void any transfer of personal property that was made by a judgment debtor to "delay, hinder or defraud." GE removed to federal district court and the Estate moved to remand. The district court remanded, concluding that the Colorado River abstention doctrine applied. The court concluded that the supplementary proceeding here was an independent action because it sought to impose new liability on new parties on wholly new legal theories based on a completely different factual matrix. Accordingly, the district court abused its discretion when it remanded the case to state court absent the rare and exception circumstances found in Colorado River, and therefore, the court reversed and remanded. View "Jackson-Platts v. General Electric Capital Corp." on Justia Law

Plaintiff, individually and on behalf of her child, filed suit under 42 U.S.C. 1983 against the Georgia Department of Human Services, Division of Family & Children Services (DFCS), Gwinnett County DFCS, and a social worker with Gwinnett County. The social worker brought this interlocutory appeal challenging the district court's denial of summary judgment, holding that she was not entitled to qualified immunity. At issue was plaintiff's substantive due process claim that the social worker violated her liberty interests in the care, custody, and management of her minor child with respect to the social worker's actions in preparing and implementing a safety plan that allegedly prohibited plaintiff from removing her child from the paternal grandmother's care. The court concluded that, in this circumstance, it could not hold that a reasonable social worker would have been on notice that her actions violated plaintiff's substantive due process rights. Accordingly, the court reversed the denial of qualified immunity to the social worker on plaintiff's substantive due process claim and remanded for further proceedings. View "Maddox v. Stephens, et al." on Justia Law

Plaintiff filed suit against defendant, in his official capacity as the Director of the Agency for Persons with Disabilities (APD), bringing a facial challenge to the constitutionality of Florida's statutory scheme for involuntarily admitting intellectually disabled persons to residential services, Florida Statutes 393.11. The court certified questions to the Supreme Court of Florida regarding the scope of the APD's obligations under the statute. View "J.R. v. Hansen" on Justia Law

This case arose when plaintiff filed suit against several companies alleging that they engaged in deception, fraud, and conspiracy in violation of Florida law based on actions they took after she was in a car accident while on vacation. The district court subsequently denied plaintiff's motion to reconsider the dismissal of her complaint and plaintiff appealed. The court remanded for the limited purpose of determining whether the parties were completely diverse but plaintiff never responded with evidence of her citizenship. The court vacated the district court's dismissal of the complaint on the merits and remanded with instructions that the case be dismissed for lack of subject matter jurisdiction because the court could not determine whether jurisdiction existed on the record before the court. View "Travaglio v. American Express Co., et al." on Justia Law

Xena, a Cayman Islands corporation, filed suit against defendants claiming that defendants improperly and impermissibly secured loans made by MFM, incorporated in the Bahamas with its principal place of business in the Bahamas, to a commercial real estate hedge fund managed by MFM in the British Virgin Islands (BVI), giving them priority over Xena's shares in the funds. The court affirmed the district court's dismissal of the complaint, finding that it had no jurisdiction or authority to determine the priority of foreign parties entitled to, or payments made from, a foreign hedge fund. View "XENA Investments Ltd. v. Magnum Fund Mgmt. Ltd., et al." on Justia Law