Justia Constitutional Law Opinion Summaries

Mariner's Cove Townhomes Association appealed the district court's grant of summary judgment on the pleadings for the United States. The district court held that the Association was not entitled to just compensation for the diminution of its assessment base resulting from the government's condemnation of fourteen properties in the Mariner's Cove Development. The court found that the Association's right to collect assessments was a property interest, but the loss of the Association's assessment base was incidental to the condemnation and was barred by the consequential loss rule. Accordingly, the court held that the loss of the Association's right to collect assessments on those properties was not compensable under the Takings Clause of the Fifth Amendment. View "United States v. Land" on Justia Law

Plaintiff sued the school district alleging that the district's decision to hire a Caucasian woman in lieu of promoting him amounted to race discrimination in violation of Title VII. The district court granted summary judgment to the district and ordered plaintiff to pay attorneys' fees. The court found no competent evidence from which a reasonable juror could infer that the district's decision to hire the woman in lieu of promoting plaintiff was motivated by impermissible racial considerations. The court held, however, that the district court's fee award constituted an abuse of discretion where the court did not agree that plaintiff's claim was frivolous, unreasonable, or without foundation. View "Autry v. Fort Bend Independent Sch. Dist." on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the school district, alleging that she was denied a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that plaintiff satisfied the court's liberal notice of appeal requirements and therefore considered the appeal on the merits. The court found that the district court complied with the IDEA's procedural requirements and, moreover, if any defects existed, they did not rise to the level of denying plaintiff a lost educational opportunity. In regards to plaintiff's substantive claim, the court analyzed the Michael F. factors and concluded that plaintiff received a FAPE. Accordingly, the court affirmed the judgment. View "R. P. v. Alamo Heights Indep Sch Dist" on Justia Law

Defendants appealed the denial of their motion for summary judgment based on qualified immunity from plaintiff's 42 U.S.C. 1983 excessive-force and state-law claims. The district court denied summary judgment, concluding that there were issues of material fact as to whether the force used by the officers was clearly excessive and objectively unreasonable. Under the applicable law, the court had no jurisdiction to review a district court's determination that there were genuine disputes of fact where the court had decided, as a matter of law, that those factual issues were material. Therefore, the court affirmed the judgment of the district court and dismissed the appeal. View "Newman v. Guedry, et al" on Justia Law

This case involved three consolidated lawsuits filed by plaintiffs who challenged the lawfulness of various ordinances enacted by the City of New Orleans regulating that city's taxicab industry. The court held that the district court abused its discretion in concluding that plaintiffs demonstrated a substantial likelihood of prevailing on their claim that sections 162-59 and 162-321 of the Municipal Code effected a regulatory taking. Therefore, the court vacated the district court's order insofar as it granted plaintiffs' motion for a preliminary injunction prohibiting enforcement of these sections. The court affirmed the district court's denial of a preliminary injunction in connection with all aspects of plaintiffs' impairment of contract claim. The court also concluded that the district court did not abuse its discretion in holding that plaintiffs failed to demonstrate that they would be irreparably injured by the denial of an injunction. Therefore, the court affirmed the district court's order insofar as it denied plaintiffs' request for a preliminary injunction enjoining enforcement of the Upgrade Ordinances. View "Melancon, et al v. City of New Orleans, et al" on Justia Law

This case arose from the death of Jason Ray Brown in the Wichita County Jail while he was a pretrial detainee. Plaintiffs appealed the district court's grant of summary judgment to Wichita County and Dr. Daniel Bolin, the physician in charge of the jail, on plaintiffs' federal civil rights claims. The court held that the district court properly analyzed this case as an episodic acts case. The court also held that the district court did not err in granting summary judgment for Dr. Bolin and Wichita County on the issue of qualified immunity. The record contained no evidence of failure of the system of medical care at the Wichita County Jail that would indicate that the the county or the doctor were deliberately indifferent in maintaining that policy. View "Brown, et al v. Wichita County" on Justia Law

Plaintiff filed a complaint, and several amended complaints, against the Louisiana Department of Corrections, asserting that threats and harassment had occurred periodically since July 2006; that he had suffered an excessive use of force in July 2006 and on November 11, 2009; that he had suffered a denial of medical care, a due process denial resulting from an extended stay in lockdown; and state law assault and battery. Because the court found that pre-filing administrative exhaustion was required pursuant to the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a), the court reversed the district court's denial of defendants' motion for summary judgment and remanded for entry of judgment dismissing the complaint. View "Gonzalez v. Seal, et al" on Justia Law

Defendants contested a summary judgment holding that the Mississippi Caller ID Anti-Spoofing Act (ASA), Miss. Code Ann. 77-3-805, violated the Commerce Clause. Plaintiffs provide nationwide third-party spoofing services to individuals and entities. In light of the carefully-drafted language in section 227(e)(1) of the Truth in Caller ID Act of 2009 (TCIA), 47 U.S.C. 227(e)(1), and legislative history, and in spite of the presumption against preemption that attached to a state's exercise of its police power, there was an inherent federal objective in the TCIA to protect non-harmful spoofing. The ASA's proscription of non-harmful spoofing frustrated this federal objective and was, therefore, conflict preempted. Accordingly, the court affirmed the judgment of the district court. View "Teltech Systems, Inc., et al v. Bryant, et al" on Justia Law

Plaintiff filed a Title VII discrimination suit against his employer, the Department of Homeland Security. At issue on appeal was whether the parties had reached an enforceable settlement. The court concluded that the district court did not abuse its discretion by finding that plaintiff was bound by the terms of his attorney's settlement offer. Further, the court never held that the Fifth Amendment's due process guarantee was implicated by defective representation in Title VII proceedings and plaintiff had introduced no evidence to suggest that his attorney's representation was less than competent. View "Quesada v. Napolitano" on Justia Law

Plaintiff appealed the district court's grant of summary judgment on his age-discrimination claims under Tex. Lab. Code Ann. 21. After defendant investigated the allegation that plaintiff falsified his work and determined that he had, defendant terminated his employment. Because plaintiff failed to present a genuine issue of material fact that his age was a motivating factor in his termination or that defendant created a hostile work environment, the court affirmed the judgment. View "Reed v. Neopost USA, Inc." on Justia Law