Justia Constitutional Law Opinion Summaries

Defendant pleaded guilty to unlawful importation of heroine and defendant subsequently appealed his sentence. The court rejected defendant's claim that the district court applied the wrong legal standard and that the government's failure to timely object to the PSR should have precluded the court's consideration of the government's objection to application of the safety valve. The court also rejected defendant's challenges to the district court's denial of relief under 18 U.S.C. 3553(f). Defendant bore the burden of proving that he had provided truthful and complete disclosure to the government, but he presented no evidence compelling such a conclusion. The district court committed no error when concluding that defendant's international-clothes-buying story was false, and that conclusion provided a proper basis for the court's rejection of defendant's claim that he was entitled to sentencing under the safety valve. Accordingly, the court affirmed the sentence.

Defendant was convicted of one count of sexual exploitation of a minor (Count 1), three counts of attempted enticement of a minor (Counts 6-8), and nine counts of witness tampering (Counts 3-5 and 9-14). Defendant subsequently appealed his convictions and sentence. The court held that defendant's claim for improper venue was without merit where defendant conducted at least some of his activity from the Eastern District of Virginia; the evidence was sufficient to support his convictions on Counts 6-8; and the district court did not err by denying defendant the right of a meaningful allocution before pronouncing sentence. Accordingly, the court affirmed the judgment.

Defendant challenged the use of his presentence report (PSR) to determine the circumstances surrounding two prior violent-felony convictions for sentencing purposes. The court found it was plain error for the district court to use the PSR's discussion of the circumstances surrounding these two convictions in applying the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), enhancement. Accordingly, the court vacated defendant's sentence and remanded for a new sentence hearing on this issue.

Plaintiff brought an action alleging that his dismissal from medical school for unprofessional behavior violated the Rehabilitation Act of 1973, 29 U.S.C. 794, and the Americans with Disabilities Act (ADA), 42 U.S.C. 12182. The district court granted summary judgment in favor of the medical school and plaintiff appealed. Because the court agreed with the district court that, with or without a reasonable accommodation of plaintiff's ADHD and anxiety disorder, plaintiff was not "otherwise qualified" to participate in the medical school's program, the court affirmed the judgment.

After defendant was indicted for two drug trafficking crimes, he filed a motion to suppress the cocaine discovered in and taken from a secret compartment in his vehicle, alleging that the search of the vehicle violated his Fourth Amendment rights. The district court granted the motion on the ground that the search exceeded the scope of defendant's consent. Because the court concluded that the district court applied the wrong legal standards for determining whether law enforcement officers had consent to search defendant's vehicle and, in any event, whether they had probable cause to search it, the court reversed and remanded for further proceedings.

Appellants challenged the Agencies' execution of a tiered review process related to planning improvements to Virginia's Interstate 81 corridor. The district court rejected appellants' challenge which alleged various constitutional and statutory violations. On appeal, appellants claimed that the Agencies were attempting to foreclose consideration of environmentally friendly alternatives for specific sections of I-81 by choosing a corridor-wide improvement concept in the first stage of the review process. The court held, however, that appellants misapprehended the Agencies' position where the Agencies planned to comply with the Stipulation in this case and the National Environment Policy Act (NEPA), 42 U.S.C. 4321 et seq., by considering site-specific alternatives to the corridor-wide concept in subsequent stages. Because there was no actual dispute here, and because appellants could not show any injury or imminent threat of injury, this suit was not justiciable. Accordingly, the court dismissed the appeal.

Plaintiff sued his employer under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., asserting that his inability to work more than eight hours per day and rotate day/night shifts as a result of physical impairments rendered him disabled under the ADA. The district court granted summary judgment to the employer and plaintiff subsequently appealed. The court held that an inability to work overtime did not constitute a "substantial" limitation on a major life activity under the ADA and the record contained no evidence indicating that plaintiff's inability to work overtime "significantly restricted" his ability to perform a class of jobs or a broad range of jobs in various classes. Therefore, the court affirmed the judgment of the district court.

Defendant appealed his convictions for willfully and knowingly making a false statement on a passport application after he prepared, signed, and submitted passport applications for his three stepsons and listed himself as the children's father. The court held that the district court did not err in concluding that the Bronston literal truth defense did not entitle defendant to judgment as a matter of law; in the context of an application for a United States passport, the word "father" was not fundamentally ambiguous; the evidence was sufficient to find that defendant understood the inquiry made by the passport application as the Government itself did and answered the question posed falsely; and the district court did not err in refusing to give defendant's proposed instruction regarding the lack of statutory definition of the word "father." Accordingly, the court affirmed the judgment of the district court.

The State sought reversal of the district court's judgment granting a writ of habeas corpus to petitioner. In granting the writ, the district court vacated the sentence of death imposed after petitioner's conviction of first degree murder. The district court concluded, inter alia, that the state courts of North Carolina unreasonably applied Strickland v. Washington, in rejecting petitioner's claim that his attorney on direct appeal failed to provide effective assistance of counsel. The court held that the district court's decision granting petitioner's petition ran contrary to the deference that federal courts were required to afford state court decisions adjudicating the merits of habeas corpus claims. Accordingly, the court reversed the district court's judgment granting the petition on the claim of ineffective assistance of counsel. The court affirmed the remainder of the district court's judgment, rejecting petitioner's Brady v. Maryland and Atkins v. Virginia claims.

Defendant was convicted and sentenced on two counts of possessing a firearm or ammunition while subject to a domestic violence protective order in violation of 18 U.S.C. 922(g)(8). Defendant appealed the district court's determination that his convictions under section 922(g)(8) did not violate the Second Amendment. The court affirmed the judgment of the district court. But because it was plain error to convict and sentence defendant on two separate counts for the simultaneous possession of a firearm and ammunition under section 922(g)(8), the court reversed defendant's conviction as to count two of the indictment, vacated his sentence, and remanded for resentencing.