Justia Constitutional Law Opinion Summaries

The district court upheld the constitutionality of the Patient Protection and Affordable Care Act, 26 U.S.C. 5000 A, which, among other things, the minimum coverage provision of the Act requires all applicable individuals to maintain minimum essential health insurance coverage or to pay a penalty. The Sixth Circuit affirmed, first holding that the plaintiffs had standing, that the case was not barred by the Anti-Injunction Act, 26 U.S.C. 7421(a), and that the matter was ripe for judicial review. The provision is a valid exercise of the legislative power under the Commerce Clause; it regulates economic activity with a substantial impact on interstate commerce. The court rejected an argument that it regulates inactivity.

Defendant, sitting in a parked car, was arrested on a warrant for carrying a concealed weapon. He set off the metal detector, but officers were unable to locate the source. After defendant used a toilet, officers found a gun near the toilet, obtained a warrant and matched defendant's DNA to that on the gun. Defendant, having waived Miranda rights, admitted that he had left the gun. The district court denied a motion to suppress. Defendant pled guilty as a felon in possession of a firearm (18 U.S.C. 922 (g)) and was sentenced to 180 months incarceration under the Armed Career Criminal Act, 18 U.S.C. 924(e). The Sixth Circuit affirmed with respect to the DNA and confession, but remanded on suppression of the gun. In blocking defendant's car, the officer conducted a "Terry" stop without objective reason to suspect defendant of criminal activity. Subsequent discovery of an open container and an outstanding warrant did not remove the taint of illegal seizure, but the DNA and confession did not retain the taint. Significant time passed between arrest and defendant's voluntary confession while lawfully in custody; there were intervening circumstances in discovery of the gun and the DNA test, done pursuant to a warrant. Because the details of a prior conviction for escape were unknown, the court remanded for reconsideration of sentencing.

After receiving assurance that her 72-acre farm operation complied with Michigan Agriculture Environmental Assurance Program cropping system requirements and with cost-effective pollution prevention practices and environmental regulations, which provides protection against nuisance suits, plaintiff planned a composting operation. State litigation concerning the plan was pending and a stop-work order was in place when neighbors started to complain about odors. After various inspections and orders, the owner received notice that the MAEAP certification was being withdrawn and filed claims against the township, its supervisor, state officials, and citizens. The district court dismissed claims against state officials, except an equal protection claim. The Sixth Circuit reversed, holding that the officials were shielded by qualified immunity. An allegation that the plaintiff is a woman and that a man was treated more favorably was insufficient to state an equal protection claim; there was a basis for each of the state's actions with respect to the plaintiff's operation and no evidence that the same facts applied to the man's operation. Nothing suggested that the defendantsâ actions were not taken in good faith and pursuant to applicable statutes.

Officers went to the house at 11:40 p.m. to execute a warrant on the son, who had failed to appear on drunk-driving charges. Waiting in a breezeway, they saw the father in the kitchen and yelled to drop the gun. The father, with poor sight and hearing, asked who the officers were. An officer fired four shots. The father died. Mother and son were cuffed and detained. The district court dismissed several claims under 42 U.S.C. 1983, but held that the officers were not shielded by qualified immunity. The Sixth Circuit affirmed denial of qualified immunity for the officer who fired. If he shot while the man was trying to comply, as claimed by the son, he violated a clearly established Fourth Amendment right to be free from deadly force. The court reversed with respect to the officer who was not a supervisor and did not shoot. The court properly retained the mother's Fourth Amendment claims; the officers had fair notice of constitutional violations inherent in subjecting a bystander to detention, excessive in duration and manner. The district court erred in not dismissing state-law gross-negligence and intentional tort claims. Although the officers may have been objectively unreasonable, they did not act in bad faith under Michiganâs subjective standard for governmental immunity.

Each summer, plaintiff leads a group of Christians at the Arab International Festival with a goal of converting Muslims to Christianity. In 2009, Dearborn police instituted a restriction that prohibited leafleting from sidewalks directly adjacent to Festival attractions and on sidewalks and roads that surround the Festivalâs core by one to five blocks; it allowed leafleting at the Festival only from a stationary booth and not while walking. The district court denied a temporary restraining order before the 2009 Festival and granted summary judgment to the defendants in 2010. The Sixth Circuit granted an injunction pending appeal for the 2010 Festival, permitting leafleting from outer sidewalks and roads, but not on sidewalks directly adjacent to attractions, then reversed with respect to the "free speech" claim. The restriction on sidewalks adjacent to attractions does not serve a substantial government interest. The city keeps those sidewalks open for public traffic and permits sidewalk vendors, whose activity is more obstructive than leafleting; the prohibition is not narrowly tailored to the goal of isolating inner areas from vehicular traffic. The city can be held liable because the Chief of Police, who instituted the leafleting restriction, created official municipal policy.

Defendant, facing the death penalty, exhausted Ohio state review and was housed in a facility for prisoners with mental illnesses. He refused to meet with attorneys to discuss collateral appeal. They filed a habeas corpus petition and a motion for a pre-petition competency hearing, at which experts agreed that defendant suffered from schizophrenia, personality disorder, and hallucinations and could not fully communicate with counsel. Two years later, an expert informed the court that defendantâs condition was worse. The court dismissed the habeas petition without prejudice and prospectively tolled the limitations period indefinitely. The Sixth Circuit remanded, noting that the "right" to competence in habeas proceedings is not constitutional, but statutory. The district court acted within its discretion in holding a pre-petition hearing and concluding that defendant was incompetent, but erred in dismissing the petition and tolling the limitations period under the Antiterrorism and Effective Death Penalty Act. With respect to the ineffective assistance claims, habeas proceedings should be stayed until defendant is competent according to 18 U.S.C. 4241. The court must examine other claims to determine whether defendantâs assistance is essential to full and fair adjudication. If not, the court should appoint a next friend to litigate those claims.

An inmate at a maximum security facility brought a pro se action under 42 U.S.C. 1983, claiming that he was injured by prison guards and received inadequate treatment. The district court entered a stay of discovery, based on defendants' claim that the inmate failed to exhaust administrative remedies, and later dismissed the case without lifting the stay. The Sixth Circuit affirmed dismissal of claims related to medical care, stating that the evidence was sufficient to establish, as a matter of law, that the defendants were not deliberately indifferent. The court reversed and remanded summary judgment on the excessive force claim, stating that the inmate's request for a video of the incident was not vague and goes to the essence of the claim.

A social worker employed by the Department was the primary case worker for plaintiffâs son, who was removed from his motherâs custody by the Department. After boy was adjudicated neglected by the juvenile court, custody was granted to his maternal great aunt and uncle. Plaintiff, who wished to take custody, claimed that the social worker misrepresented his desire and ability to parent and impeded his ability to participate in custody proceedings. The district court denied the social worker's motion for summary judgment on claims under 42 U.S.C. 1983. The Sixth Circuit reversed, holding that the social worker is absolutely immune from suit for her participation in juvenile court proceedings, regardless of whether she conducted an inadequate investigation or knowingly made false statements. Because the social worker's conduct neither caused any deprivation of the plaintiff's interest in family integrity, nor interfered with the process, qualified immunity barred remaining claims. The juvenile court was responsible for the "deprivation" and the plaintiff had notice and an opportunity to be heard.

Convicted of killing a Detroit police officer in 1993 and sentenced as a habitual offender to consecutive terms of 40-80 years in prison for murder and five years for a felony firearm conviction, the defendant exhausted his opportunities for relief in state court. Following a remand from appeal of a dismissal for untimely filing, the district court denied a petition for habeas corpus. The Sixth Circuit remanded. Reversal is required because defense counsel faile to file a timely brief in the direct state court appeal and that court denied direct appeal. Review of denial of collateral relief, which does not involve the same rights as direct appeal, is not an adequate substitute. Defendant is not entitled to habeas relief on his jury coercion claim, which was based on the trial judge's urging that the jury continue deliberations. In light of the entire supplemental instruction, the trial courtâs determination that the Allen charge was not coercive was not an unreasonable application of federal law.

The government introduced evidence of defendant's prior sale of cocaine during his trial on charges of being a felon in possession of a firearm and ammunition, (18 U.S.C. 922(g)), possession with the intent to distribute 50 grams or more of cocaine base, (21 U.S.C. 841(a)(1) and 841(b)(1)), and possession of firearms in furtherance of a drug trafficking crime, (18 U.S.C. § 924(c)(1)). The Sixth Circuit affirmed. The district court acted within its discretion in holding that the prior acts evidence was admitted for the proper purpose of establishing specific intent; determined that its probative value was not outweighed by its prejudicial effect, based on the evidence and the defense; and gave two strong cautionary instructions to the jury. Any error would be harmless in light of the "wealth" of alternative evidence, including defendant's own statements. The sentence of 420 months was appropriate, in light of the defendant's history.