Justia Constitutional Law Opinion Summaries

Plaintiff, aged 76, filed suit under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq, and state law, contending that Securitas fired him because of his age. Plaintiff cited evidence that prior to his termination, Securitas supervisors showed age animus through negative comments regarding plaintiff's age. Plaintiff adduced enough evidence to raise genuine doubt as to the legitimacy of Securitas's motive, even if that evidence did not directly contradict or disprove Securitas's articulated reasons for its actions. Accordingly, the court reversed the district court's grant of summary judgment in favor of Securitas, concluding that there were genuine issues of material fact concerning pretext. View "Johnson v. Securitas Security Services" on Justia Law

Plaintiffs filed suit against the city alleging that the city's zoning scheme violated the First and Fourteenth Amendments. The court concluded that the zoning ordinances at issue were content-neutral, time, place and manner regulations subject to intermediate scrutiny; the zoning scheme was narrowly tailored to serve a substantial government interest; and there were reasonable alternative avenues in which plaintiffs could operate an adult entertainment business despite the zoning ordinances. Accordingly, the zoning ordinances did not violate plaintiffs' constitutional rights and the court affirmed the judgment of the district court. View "Peterson, et al. v. City of Florence" on Justia Law

After a patient's death, the patient's family sued the VA for medical malpractice. The VA settled with the family and determined that the settlement was "for the benefit of" plaintiff, who was a treating physician. Plaintiff then filed suit against the VA alleging violations of his due process rights and violations of the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq. The court concluded that the district court did not err by dismissing the procedural due process claim because plaintiff failed to plead the deprivation of a constitutionally protected interest; the district court did not err by dismissing plaintiff's substantive due-process claim because plaintiff's pleadings were insufficient; the VA's factfinding procedures were adequate and the district court properly rejected de novo review; the district court did not grossly abuse its discretion by denying plaintiff's motion to supplement the record; and the VA's decision was not arbitrary or capricious, and the district court did not err by granting summary judgment. Accordingly, the court affirmed the judgment of the district court. View "Rochling v. Dept. of VA, et al." on Justia Law

Plaintiff filed suit under Titles I and V of the Americans With Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq., against his employer and various state employees, alleging that defendants retaliated against him in response to a prior discrimination suit that he had filed against them. The court dismissed the appeal for lack of jurisdiction because sovereign immunity barred plaintiff's claims for money damages against defendants. View "Lors v. Dean, et al." on Justia Law

Plaintiffs, four former inmates, filed suit under 42 U.S.C. 1983, seeking monetary and injunctive relief for detention beyond their release dates. The court affirmed the district court's grant of qualified immunity to the DOC Director on the individual capacity damage claims because, under the circumstances, the law did not fairly warn him that the amount of time spent recalculating thousands of release dates, including plaintiffs', recklessly disregarded their constitutional right to release. View "Scott v. Baldwin" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against St. Louis police officers for, inter alia, arresting her on false charges and conspiring to hide it. The court concluded that the record was sufficient for a reasonable factfinder to find that Defendants Harris and Isshawn-O'Quinn participated in a section 1983 conspiracy to violate plaintiff's clearly established constitutional rights by, inter alia, conspiring with other officers to prevent plaintiff from filing a section 1983 action following her false arrest. Accordingly, the district court did not err in denying qualified immunity to these defendants. The court dismissed the appeal by the municipal defendants for lack of jurisdiction where the issues raised by these defendants were not inextricably intertwined with the question of qualified immunity. View "S.L. v. Board of Police Commissioners, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that a detective submitted a false statement of probable cause to secure a warrant for his arrest and that an assistant county attorney approved the warrant application even though it lacked probable cause. The detective sought a warrant for plaintiff's arrest, alleging that he had knowingly violated the state registration requirements for predatory offenders or intentionally provided false information. In light of the facts known to the detective when he applied for the warrant and the ambiguity of the statutory language, the court could not say that no reasonably competent officer would have applied for an arrest warrant. Accordingly, the court concluded that the detective was entitled to qualified immunity where the belief that probable cause existed to arrest plaintiff for failing to register his Belize address as his primary address - even if that belief was mistaken - was objectively reasonable. Even if no probable cause existed to support the warrant for plaintiff's arrest, the attorney was nonetheless entitled to absolute immunity because his acts in reviewing and approving the complaint against plaintiff were taken to initiate the criminal prosecution. Accordingly, the court affirmed the judgment. View "Saterdalen v. Spencer, et al." on Justia Law

Defendant, an enrolled member of the Turtle Mountain Band of the Chippewa Indians, entered into a satellite television contract with DISH but used his daughter's credit card to open his account. After defendant stopped making payments, DISH charged the daughter's credit card. The daughter sued DISH in state court but DISH removed to federal court where it filed a third party complaint against defendant. Defendant then filed an abuse of process claim against DISH in tribal court. At issue on appeal was DISH's challenge to the district court's denial of its motion for a preliminary injunction enjoining the tribal court from conducting a trial on defendant's abuse of process claim. The court affirmed the district court's judgment because it was not "plain" that the tribal courts lacked jurisdiction over defendant's abuse of process complaint. View "DISH Network Service L.L.C. v. Laducer, et al." on Justia Law

Voters filed suit against Officials challenging the process by which Officials confirmed the eligibility of voters who register on election day (election day registrants or EDRs). Voters also challenged a provision of the Minnesota Constitution denying the right of persons under guardianship to vote, as well as the sufficiency of notice afforded to such persons under certain Minnesota statutes. The court concluded that Voters could not prevail on their 42 U.S.C. 1983 claims based on Officials' failure to verify EDR's voting eligibility before allowing EDRs to cast their votes where Voters raised no allegations of the "aggravating factors" identified in Pettengill v. Putnam County R-1 School District; alleged no discriminatory or other intentional, unlawful misconduct by Officials sufficient to implicate section 1983; and alleged no defects causing Minnesota's voting system to be so "fundamentally unfair" that relief under section 1983 would be appropriate. Further, Voters lacked standing to raise their remaining claims where the amended complaint failed to allege that any plaintiff has been denied the right to vote by a constitutional provision barring persons under guardianship from voting. Accordingly, the court affirmed the district court's dismissal of Voters claims and denial of their motion for summary judgment as moot. View "Minnesota Voters Alliance, et al. v. Ritchie, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the County after a jail operated by the County failed to provide him with necessary anti-seizure medication while he was incarcerated. In this instance, plaintiff presented no evidence to suggest that the County's policymaking officials would have received notice of the denial of his medication in the morning at issue and made a deliberate choice to ignore or tacitly authorize the denial in the course of those few hours. Accordingly, the court affirmed the grant of summary judgment to the County because plaintiff failed to present evidence of a continuing, widespread, persistent pattern of unconstitutional misconduct by the governmental entity's employees. View "Johnson, Jr. v. County of Douglas, NE" on Justia Law