Justia Constitutional Law Opinion Summaries

Plaintiff filed suit alleging, inter alia, that she was subjected to a hostile work environment based on her race. The court concluded that the evidence did not support a hostile work environment claim and Denton County was entitled to judgment as a matter of law; because plaintiff failed to plead facts sufficient to survive a motion to dismiss on her failure to promote claim, the district court did not err by denying discovery and dismissing the suit against the Individual Defendants; and, therefore, the court reversed in part and affirmed in part. View "Williams-Boldware v. Denton County Texas" on Justia Law

Plaintiffs, detainees, filed Bivens claims against defendant, a border officer, for violations of their Fourth Amendment right to be free of unreasonable searches and seizures. The district court granted defendant's motion to dismiss based on qualified immunity and plaintiffs appealed. The court concluded that plaintiffs were detained as excluded aliens for varying amounts of time and neither of the claims involved physical abuse. Therefore, the claims fell within the confines of entry fiction, and the Fourth Amendment was inapplicable; the detention did not violate constitutional rights; and the district court properly dismissed these claims under Rule 12(b)(6). Even if plaintiffs were in fact U.S. citizens, dismissal was proper because defendant enjoyed qualified immunity where plaintiffs pointed to no authority clearly establishing that defendant's actions in detaining, even for as long as ten hours, individuals who presented facially valid documentation, plus the use of unspecified threats and insults during interrogation, violated the Constitution. Accordingly, the court affirmed the judgment of the district court. View "Castro, et al. v. Cabrera" on Justia Law

Petitioner appealed the denial of his petition for writ of habeas corpus under 28 U.S.C. 2241. Petitioner challenged the constitutionality of the Inmate Financial Responsibility Program (IFRP), a program administered by the Bureau of Prisons (BOP), that grants inmates certain privileges if they participate in the program by paying off court-ordered financial obligations. Petitioner argued that his placement into IFRP "refuse" status violated his First Amendment rights because he could not make the minimum payment under the IFRP and pursue his various claims and appeals in the judicial system. The court concluded that this argument failed because petitioner could not demonstrate an actual injury. Because the IFRP was reasonably related to legitimate penological interests, it does not violate petitioner's equal protection rights. Finally, the court found that the imposition of the "refuse" conditions in 28 C.F.R. 545.11(d) did not violate an inmate's liberty interests under the Due Process Clause. Accordingly, the court affirmed the district court's denial of the petition. View "Driggers v. Cruz, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, challenging the constitutionality of Texas Government Code 501.063, which provides that inmates must pay a $100 annual health are service fee when they receive medical treatment in the prison system. After affirming the dismissal of Governor Perry because he was not a proper defendant, the court turned to the merits of the case. The court concluded that the complaint did not state sufficient facts to support an Eighth Amendment claim under the theory that defendant was denied medical care or that the fee required him to decide between obtaining medical care or basic necessities; plaintiff's due process claims failed where the notice provided was constitutionally adequate and the discrepancy between the posted notice and the statute did not render the notice inadequate; plaintiff failed to show that the taking of funds from his inmate trust fund account to pay for his medical care was unreasonable in light of the goal of controlling the prison budget and, therefore, plaintiff's claims under the Fourth Amendment failed; and plaintiff waived his ex post facto claim, as well as his other miscellaneous claims. Accordingly, the court affirmed the district court's grant of defendant's motion to dismiss. View "Morris v. Livingston" on Justia Law

EMS appealed the district court's order denying its motion to remand its suit against the City to the state court from which it was removed. The court concluded that removal was improper because none of the claims in EMS's state court civil action satisfied either the federal question or diversity requirements of original jurisdiction; the district court's prior jurisdiction over the claims asserted in City v. CLECO, which were now dismissed, did not vest the district court with jurisdiction over EMS's claims; regardless of how factually intertwined with EMS's suit, the district court's retention of jurisdiction over the post-settlement matters could not substitute for original jurisdiction for the purpose of supplemental jurisdiction under 28 U.S.C. 1367 or removal under section 1441, given that EMS's claims were not asserted in the same proceeding as the claims in City v. CLECO; and, if Baccus v. Parrish retained any precedential value, it was distinguishable and inapposite in this instance. Accordingly, the court reversed and remanded. View "Energy Mgmt. Servs. v. City of Alexandria" on Justia Law

Plaintiff, the former employee of the standing trustee for the Western district of Louisiana (defendant), filed suit against defendant alleging violation of the Louisiana Employment Discrimination Law (LEDL), Louisiana Revised Statutes 23:301-03, 23:323. Defendant removed the suit to federal court under the federal officer removal statute, 28 U.S.C. 1442(a)(1). The district court determined that removal was proper, and that defendant should be granted summary judgment because he did not qualify as an "employer" under the LEDL. The court concluded that defendant acts under officers of the United States and fell within section 1442(a)(1)'s purview, and defendant has averred a colorable federal defense and was entitled to remove this case under the federal officer removal statute. The court held that summary judgment was proper because defendant did not qualify as an employer under the LEDL. Accordingly, the court affirmed the judgment of the district court. View "Bell v. Thornburg" on Justia Law

Plaintiff appealed the district court's grant of summary judgment on her retaliation claim, which she claimed resulted from her complaints about sexual harassment. The court held that there were genuine disputes of material fact as to whether the conduct at issue created a hostile work environment in violation of Title VII, and, if so, whether plaintiff's complaint about that conduct was causally related to her termination. Accordingly, the court vacated and remanded for further proceedings, concluding that plaintiff had made out a prima facie case on her retaliation claim. View "Royal v. CCC& R Tres Arboles, L.L.C." on Justia Law

Plaintiff filed suit against the United States and others, alleging violations of her religious rights under Title VII, 42 U.S.C. 2000e et seq., and the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb et seq. Plaintiff lost her job by failing to comply with the applicable regulations or to receive an appropriate waiver when she wore a kirpan (a Sikh ceremonial sword) to work. The court affirmed the district court's grant of summary judgment on plaintiff's Title VII claim where her employer's, the IRS, failure to accommodate plaintiff did not violate Title VII as a matter of law. The court reversed and remanded plaintiff's RFRA claim for further development of evidence concerning the government's compelling interest in enforcing against plaintiff the statutory ban on weapons with blades exceeding 2.5 inches. View "Tagore v. United States" on Justia Law

Plaintiff filed suit against PSEG alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and other statutes. The court concluded that the district court did not err in submitting the first special verdict question - "Was a Plaintiff a qualified individual with a disability?" - where the jury-instruction definitions of "disability" and "qualified individual" properly conformed to the ADA Amendments Act of 2008 (ADAAA). The court also concluded that the district court did not err in submitting the third special verdict question - "Was a Plaintiff a qualified individual with a disability?" Because the district court did not abuse its discretion in either jury interrogatory, there was no need to consider whether an error required reversal. Accordingly, the court affirmed the judgment of the district court. View "Neely v. PSEG Texas LP, et al." on Justia Law

Planned Parenthood and others filed suit seeking a permanent injunction against the enforcement of two amendments to the laws of Texas concerning abortions (H.B. 2). Two provisions of H.B.2 were at issue: first, the requirement that a physician performing or inducing an abortion have admitting privileges at a hospital; and second, the limitations on the use of abortion-inducing drugs to a protocol authorized by the FDA. The district court held that parts of the legislation were unconstitutional and granted the requested injunctive relief. The State appealed and filed an emergency motion to stay the district court's permanent injunction. The court concluded that the State has made a strong showing that it was likely to succeed on the merits in regards to the hospital-admitting privileges provision. There was a substantial likelihood that the State would prevail in its argument that Planned Parenthood failed to establish an undue burden on women seeking abortions or that the hospital-admitting-privileges requirement created a substantial obstacle in the path of a woman seeking an abortion. The court also concluded that the State has made a strong showing of likelihood of success on the merits, at least in part, as to its appeal of the injunction pertaining to medication abortions. Accordingly, the court stayed the injunction pertaining to medical abortions with certain exceptions. The State has made an adequate showing as to the other factors considered in determining a stay pending appeal. Accordingly, the court granted the motion for stay pending appeal. View "Planned Parenthood, et al. v. Abbott, et al." on Justia Law