Justia Constitutional Law Opinion Summaries

Petitioners appealed from the district court's denial of habeas corpus relief, contending that, at their sentencing for armed robbery of the Sunday worship services at a North Carolina church, the state trial judge impermissibly made references to religion, thereby violating their rights to due process. The court affirmed the denial of the petition where defendants' choice to target a church during weekly services imbued their crime with an undeniably religious character; crimes of that nature carried special hazards for the freedom of all faiths to worship undisturbed; and the trial judge's comments reflected distinctive harms to the community of the particular crime that defendants chose to commit and was not an unreasonable application of clearly established Federal law.

Plaintiff, a Virginia non-profit corporation organized under section 527 of the Internal Revenue Code, commenced this action against the Commission and the Department of Justice, contending that it was "chilled" from posting information about then-Senator Obama because of the vagueness of a Commission regulation and a Commission policy relating to whether plaintiff had to make disclosures or was a "political committee." Plaintiff asserted that it was not subject to regulation but feared the Commission could take steps to regulate it because of the vagueness of 11 C.F.R. 100.22(b) and the policy of the Commission to determine whether an organization was a political action committee by applying the "major purpose" test on a case-by-case basis. Plaintiff alleged that the regulation and policy were unconstitutionally broad and vague, both facially and as applied to it, in violation of the First and Fifth Amendments. The court applied the "exacting scrutiny" standard applicable to disclosure provisions and affirmed the district court's finding that both the regulation and the policy were constitutional.

After Racheal Wilson, a new recruit for the Baltimore City Fire Department, tragically died during a "live burn" training exercise, her survivors and estate commenced this action under 42 U.S.C. 1983 against defendants, alleging that the fire department violated Wilson's substantive due process rights by staging the exercise with deliberate indifference to her safety, so as to shock the conscience. The court concluded that because the complaint did not purport to allege that the fire department staged the live burn training exercise with the purpose of causing harm to Wilson or to any other recruit, it fell short of alleging a substantive due process violation in the context of the facts alleged, even though it might well allege causes of action under state law, as the complaint purported to do in other counts.

Plaintiff, an inmate, appealed the district court's dismissal of his complaint for failure to state a claim on which relief could be granted. Plaintiff asserted that the North Carolina Department of Corrections at Alexander Correctional Institute's failure to enforce its grooming policy put inmates at risk for contracting various infections. Plaintiff moved to proceed in forma pauperis (IFP) on appeal, despite the fact that the district court's dismissal of the underlying claim was plaintiff's third dismissal for failure to state a claim. Because counting the district court's dismissal as a third strike under 28 U.S.C. 1915(g) would effectively insulate the dismissal from appellate review, the court granted plaintiff's motion to proceed IFP on appeal.

Defendant was convicted of various offenses stemming from an extensive mortgage fraud conspiracy. On appeal, defendant challenged the district court's evidentiary rulings, loss calculation, and order directing him to reimburse his court-appointed attorneys' fees. The court affirmed the district court's judgment on the first two issues, but vacated the court's reimbursement order. Defendant also argued that his money laundering convictions must be reversed under United States v. Santos. Applying Santos, as interpreted by United States v. Halstead, to the facts underlying defendant's substantive money laundering convictions, the court agreed and therefore reversed those convictions.

Petitioner, convicted of first-degree murder, appealed the district court's denial of his 28 U.S.C. 2254 petition. The district court ruled that the petition was time-barred and, in the alternative, the petition was denied on its merits. The court was content to assume without deciding that petitioner's claims were not time-barred. The court held, however, that petitioner's claims lacked merit and affirmed the judgment of the district court.

Defendant, a citizen of Somalia, was convicted of unlawful wounding and grand larceny. 8 U.S.C. 1226(c) required the mandatory federal detention, without the possibility of bond, of certain deportable criminal aliens "when" those aliens were released from other custody. At issue was whether, as the district court held, defendant, a deportable criminal alien who was not immediately taken into federal custody upon his release from other custody, was exempt from section 1226(c)'s mandatory detention provision and therefore was entitled to a bond hearing. The court held that the BIA's interpretation of section 1226(c) in In re Rojas was reasonable, and must be afforded deference. Moreover, the Government's supposed failure to comply with a statutory immediacy requirement - when the statute did not specify a consequence for such noncompliance - did not bestow a windfall upon criminal aliens. Therefore, defendant remained subject to mandatory detention.

Defendants, all Somalis, were convicted, among other things, of the crime of piracy under 18 U.S.C. 1651 after they launched an attack on the USS Nicholas on the high seas between Somalia and the Seychelles. On appeal, defendants challenged their convictions and sentences on several grounds, including that their attack on the USS Nicholas did not, as a matter of law, amount to a section 1651 piracy offense. Because the district court correctly applied the United Nations Convention on the Law of the Sea (UNCLOS), U.N. Convention on the Law of the Sea, art. 101, definition of piracy as customary international law, the court rejected defendants' challenge to their Count One piracy convictions, as well as their mandatory life sentences. Defendants raised several additional appellate contentions which the court also rejected. Accordingly, the court affirmed the convictions and sentences of each of the defendants.

Plaintiff appealed the district court's dismissal of its complaint, alleging that Arlington County's sign ordinance violated the First Amendment. Plaintiff had commissioned a painting described as including "happy cartoon dogs, bones, and paw prints" and the county subsequently notified plaintiff that the painting violated the sign ordinance. The court agreed with the district court that the ordinance was a content-neutral restriction on speech that satisfied intermediate scrutiny. Finding no merit to the other constitutional challenges, the court affirmed the judgment.

Defendant appealed his conviction and sentence for making, or aiding and abetting the making of, a false entry in a bankruptcy-related document. The charges arose from a fraudulent scheme directed by the co-defendant where the co-defendant established companies and maintained control over them by installing his associates as their nominal heads. The co-defendant then convinced individuals to invest in the companies through loans that he represented would be repaid in interest, but these companies in fact had no legitimate business activity and he misappropriated the invested funds for personal use. Defendant was the manager of one such company. On appeal, defendant contended that the district court erred in failing to provide several requested jury charges, the prosecutor committed reversible misconduct, defense counsel provided ineffective assistance, and the district court improperly refused to apply a mitigating role adjustment in sentencing. The court found defendant's arguments to be either without merit or noncognizable and affirmed the judgment.