Justia Constitutional Law Opinion Summaries

Press intervenors appealed the district court's decision denying them access to court proceedings and a sealed internal police document (Report) and continuing to redact parts of hearing transcripts. The court concluded that the district court erred by declining to order release of the full transcript of the contempt hearing, but that given the minimal relevance of portions of the Report that were not testified to at the contempt hearing to the substance of that proceeding, the Report did not become a judicial document to which the First Amendment right applied. Accordingly, the court affirmed as to the Report, reversed as to the hearing transcript; and remanded for further proceedings. View "Newsday v. County of Nassau" on Justia Law

Plaintiffs filed suit to contest a wage freeze imposed in 2011 on Nassau County employees by the Nassau Interim Finance Authority (NIFA). The police unions contended that the wage freeze was imposed in violation of the Contracts Clause, Article I, Section 10 of the Constitution, and that the authority conferred on NIFA to impose such a freeze had expired under the terms of the applicable statute, N.Y. Pub. Auth. Law 3669(3). The district court granted summary judgment to the police unions on their state law claim without reaching the constitutional question. The court vacated and remanded, concluding that the district judge should have declined to reach the pendant state law claim, which required it to interpret, as a matter of first impression, an important state legislative scheme to prevent the fiscal demise of Nassau County. View "Carver v. Nassau County Interim Finance" on Justia Law

Plaintiff, representative of the estate of her deceased son, filed suit against the City of New York, police officers, and others, alleging that they were liable for her son's death. A jury found in favor of defendants. The court held that, where a municipality acted in a governmental capacity, a plaintiff could not recover without proving that the municipality owed a "special duty" to the injured party. The plaintiff bears the burden of proving a special relationship, and where the plaintiff failed to meet this burden, the analysis ended and liability could not be imputed to the municipality that acted in a governmental capacity. The distinction between nonfeasance and misfeasance was irrelevant to the analysis and the existence of a special relationship was a question of law that could be properly submitted to the jury. In this instance, the court found no error entitling plaintiff to a new trial and affirmed the judgment of the district court. View "Velez v. City of New York" on Justia Law

Plaintiff filed suit against New York state prison officials alleging that they substantially burdened his First Amendment right to free exercise of religion in violation of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. 2000cc-1, and that they infringed his due process and First Amendment rights in violation of 42 U.S.C. 1983. This appeal arose when defendants instigated a disciplinary proceeding against plaintiff, an inmate and a Muslim, after an interaction in which plaintiff gave Chaboty a Quran. The court concluded that plaintiff's RLUIPA claim must fail because RLUIPA did not authorize monetary damages against state officers in their official capacities, and did not create a private right of action against state officers in their individual capacities. Therefore, the court affirmed the district court's dismissal of plaintiff's RLUIPA claim. View "Washington v. Gonyea" on Justia Law

Time Warner petitioned for review of the FCC's 2011 order promulgated under section 616(a)(3) and (5) of the Communications Act of 1934 (Communications Act), as amended by the Cable Television Consumer Protection and Competition Act of 1992 (Cable Act), 47 U.S.C. 536(a)(3), (5). Section 616(a)(3) and (5) and that part of the 2011 Order establishing the standard for demonstrating a prima facie violation of these statutory provisions (the program carriage regime) were intended to curb anticompetitive behavior by limiting the circumstances under which a distributor of video programming could discriminate against unaffiliated networks that provided such programming. The court concluded that the program carriage regime did not violate the First Amendment where its case-specific standards for identifying affiliation-based discrimination served important government interests in promoting competition and diversity in an industry still posing serious competitive risks and were narrowly tailored not to burden substantially more speech than necessary to further those interests. The court concluded, however, that the 2011 Order was substantive and therefore subject to the notice-and-comment requirements of the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq. Because the FCC failed to comply with such requirements, the court granted the petition for review insofar as it raised an APA challenge. View "Time Warner Cable Inc. v. FCC" on Justia Law

This case arose when appellant settled an environmental enforcement action brought against him by the United States through a consent decree providing, inter alia, that defendant would pay the government an amount equal to the fair market value of a parcel of real property owned by appellant. At issue on appeal was whether a district court, under the All Writs Act, 28 U.S.C. 1651(a), and the Anti-Injunction Act, 22 U.S.C. 2283, had the authority to enjoin a party from litigating in state court issues arising out of the consent decree which settled the civil action brought against the party in federal court by the United States. The court held that the Anti-Injunction Act did not permit the district court in this case to enjoin appellant's state court suit. Accordingly, the court vacated the injunction, concluding that the district court erred by relying on the "in aid of jurisdiction" exception to the Anti-Injunction Act in enjoining appellant's state court suit. View "United States v. Manne" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the City of New York and police officers, asserting claims of constitutional torts involving arrest without probable cause and malicious prosecution. In regards to the timeliness of plaintiff's suit against the John Doe officers, the court concluded that plaintiff waived the arguments he raised on appeal by failing to raise them in the trial court. The court concluded that plaintiff's claims of municipal liability against the City should not have been dismissed by reason of Officer Symon's entitlement to qualified immunity and the untimeliness of plaintiff's suit against the Doe defendants. Accordingly, the court vacated the judgment in favor of the City and remanded those claims for further consideration. View "Askins v. City of New York et al." on Justia Law

This appeal arose from an order of the district court denying Argentina's motion to dismiss a petition to confirm an arbitration award filed by Blue Ridge on foreign immunity grounds. The court held that it had jurisdiction to consider the district court's rejection of Argentina's assertion of foreign immunity under the collateral order doctrine; the court declined to exercise appellate jurisdiction to consider whether the district court erred in concluding that Blue Ridge, as an assignee, could state a claim to confirm the International Centre for the Settlement of Investment Disputes award because that issue was not "inextricably intertwined" with the district court's foreign sovereign immunity decision; the district court correctly concluded that Argentina waived its foreign sovereign immunity pursuant to two separate and independent exceptions to the immunity from suit provided by the Foreign Sovereign Immunities Act: the implied waiver exception and the arbitral award exception, 28 U.S.C. 1605(a)(1), (2), and (a)(6). Accordingly, the court affirmed insofar as the district court concluded that Argentina waived its foreign sovereign immunity and remanded for further proceedings. View "Blue Ridge Investments, L.L.C. v. Republic of Argentina" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 after her arrest and detention pursuant to a material witness warrant. On appeal, plaintiff challenged the district court's denial of her motion for reconsideration as to the individual defendants. Plaintiff argued that the district court erred in finding that detaining an individual for two days pursuant to a material witness warrant was a prosecutorial function entitled to absolute immunity. The court agreed and held that defendants were not entitled to absolute prosecutorial immunity with respect to plaintiff's allegation that she was unlawfully detained for investigative interrogation. In the absence of any discovery by plaintiff, the record was insufficiently developed at this stage. Accordingly, the court vacated and remanded for further proceedings. View "Simon v. City of New York, et al." on Justia Law

Entergy, owner and operator of the Vermont Yankee Nuclear Power Station, filed suit against Vermont, raising claims challenging Vermont statutes governing Vermont Yankee (Acts 74, 160, and 189) and other claims related to Vermont's attempt to condition its grant of permission to operate Vermont Yankee on the execution of a power purchase agreement that favored Vermont retail consumers. The court affirmed the district court's grant of declaratory judgment that Act 74 and Act 160 were facially preempted by the Atomic Energy Act, 42 U.S.C. 2011-2281; reversed the district court's determination that Vermont's efforts to condition a new Certificate of Public Good for Vermont Yankee on the execution of a favorable power purchase agreement violated the dormant Commerce Clause; affirmed the district court's determination that Entergy's challenge under the Federal Power Act, 16 U.S.C. 791-828c, was unripe; affirmed the district court's grant of a permanent injunction enjoining defendants from enforcing sections 6522(c)(2) or 6522(c)(4) in title 10 of the Vermont Statutes, as enacted by Act 74, or sections 248(e)(2), 248(m), or 254 in title 30 of the Vermont Statutes, as enacted by Act 160; and vacated the district court's permanent injunction enjoining defendants from conditioning the issuance of a Certificate of Public Good on the execution of a below-wholesale-market power purchase agreement between Entergy and Vermont utilities or otherwise requiring Vermont Yankee to sell power to Vermont utilities at preferential rates.View "Entergy Nuclear Vermont Yankee v. Shumlin" on Justia Law