Justia Constitutional Law Opinion Summaries

Plaintiffs filed these actions to enjoin enforcement of Ordinance No. 5165, which limited hiring and providing rental housing to "illegal aliens" and "unauthorized aliens," terms defined by the Ordinance. The district court severed and enjoined enforcement of certain rental provisions, concluding that they were preempted by the Immigration and Nationality Act (INA), 8 U.S.C. 1101 et seq., and violated the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq. The court concluded, inter alia, that plaintiffs have failed to establish that any of the Ordinance's rental provisions were facially preempted by federal law; the district court did not abuse its discretion in denying the Martinez Plaintiffs' motion to correct their "oversight or omission" in failing to plead a distinct FHA claim; because one of the Keller Plaintiffs had Article III standing to assert an FHA disparate impact claim, the court had jurisdiction to consider the merits of the claim; on the merits, the Keller Plaintiffs could not identify "a viable alternative means" that would not have the same "discriminatory" effect and disparate impact on the portion of unlawfully presented aliens who are Latino and, therefore, this claim must be dismissed; and the Martinez Plaintiffs failed to prove their belated claims of actual conflict. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Keller, Jr., et al. v. City of Fremont, et al." on Justia Law

A bankruptcy court ordered that the Laurel Avenue house be vacated and authorized U.S. Marshals to physically remove plaintiff, the debtor's son, from the home. On appeal, plaintiff challenged the dismissal of his suit, which alleged, inter alia, that his constitutional rights were violated when the house, its contents, and his person were searched and seized. The court found no error in the dismissal of plaintiff's 42 U.S.C. 1983 claim against the federal defendants where he did not allege a Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics action in the amended complaint, nor did he seek to amend to add the claim; plaintiff's section 1983 claim failed against the city and the city's officers where plaintiff failed to set forth sufficient facts to show a direct causal link between the city's policy or custom and the alleged violation of his constitutional rights; the district court did not err in dismissing his tort claims against the trustees under the doctrine established in Barton v. Barbour, which established that an equity receiver could not be sued without leave of the court that appointed him; and because the dismissal of plaintiff's federal claims was proper, the court found no abuse of discretion in the district court's decision to decline supplemental jurisdiction over the remaining state law claims. Accordingly, the court affirmed the judgment. View "Alexander v. Hedback, et al." on Justia Law

Plaintiff, an involuntarily committed mental patient, sued various officials alleging that a facility-wide change in policy deprived him of a previously held ability to walk unsupervised around an unsecured area of the grounds at the Center where he was committed. Where, as here, it was difficult even to characterize the claimed restriction as a bodily restraint, the balancing test of the professional-judgment standard necessarily lead the court to conclude that plaintiff's claims failed. Even if plaintiff had articulated a protected liberty interest, there was no substantive due process violation where nothing about the policy at issue shocked the conscience. Therefore, the court affirmed the district court's dismissal of plaintiff's due process claim. View "Montin v. Gibson" on Justia Law

Petitioner appealed his convictions, from four separate trials, of criminally transmitting the HIV virus in violation of Iowa Code 709C.1. On appeal, petitioner challenged the district court's denial of his 28 U.S.C. 2254 petition for habeas relief. The court concluded that the statute was not unconstitutionally vague as applied to him because he knew his HIV status to be "positive" and engaged in the type of "intimate contact" that the statute was plainly intended to prohibit; petitioner was precluded from asserting a void-for-vagueness challenge to the statute based on the hypothetical situations posed in his petitions and brief; and petitioner was precluded from asserting an overbreadth challenge to the statute because he did not raise any First Amendment concerns. Accordingly, the court affirmed the district court's denial of habeas relief. View "Musser v. Mapes" on Justia Law

Indigo and one of its employees filed suit against Advanced and Lile, alleging breach of contract, negligence, conspiracy, and violations of federal law on the theory that Advanced and Lile had intentionally delayed payments on valid insurance claims. Indigo argued on appeal that, despite receiving full reimbursement from the receiver, it suffered an injury because a monthly retention amount it had paid to Advanced was neither credited towards the employee's medical costs nor repaid by Indigo. The court agreed with the district court that Indigo failed to establish standing because Indigo failed to show how any injury had arisen, or might arise in the future, from the alleged conduct. View "Indigo LR LLC, et al. v. Advanced Ins. Brokerage, et al." on Justia Law

Plaintiff sued the City under 42 U.S.C. 1983 after she was sexually assaulted by a City policy officer. The officer was charged with first degree sexual assault and subsequently terminated from the police force. On appeal, plaintiff challenged the district court's grant of summary judgment to the City. The court concluded that a jury could reasonably infer, based on the evidence, that the City's custom of ignoring violent misconduct and failing to supervise or discipline officers was a moving force behind the officer's assault on plaintiff. Accordingly, the court vacated the district court's grant of summary judgment and remanded for further proceedings. View "Doe v. City of Marianna, AR" on Justia Law

Plaintiff appealed the district court's dismissal with prejudice of his case under Federal Rule of Civil Procedure 41(b). Plaintiff contended that the district court abused its discretion by dismissing the "extreme sanction" of dismissing his case with prejudice where the record showed neither "intentional delays" nor "contumacious conduct" on his part. The court concluded, based on the circumstances, that the district court abused its discretion in denying the motion for continuance and therefore erred in dismissing the case with prejudice and denying the motion to reconsider. The record showed no evidence of why the district court could not have accommodated its schedule, defendant's schedule, and plaintiff's schedule in continuing the case to a later date and plaintiff had a good basis for a continuance. View "DiMercurio v. Malcom" on Justia Law

Plaintiff sued her former employer and others after she was terminated, alleging federal claims of discrimination based on her gender, religion, and disability, as well as defamation under state law. On appeal, plaintiff challenged the district court's adverse grant of summary judgment on the remaining claims that were not dismissed. The court concluded that the district court did not err in granting summary judgment on plaintiff's discrimination claims to Trumann Health where, under the McDonnell Douglas analysis, Trumann Health articulated a legitimate, nondiscriminatory reason for firing her and plaintiff did not show other similarly situated employees were more favorably treated; the district court properly granted summary judgment on plaintiff's libel claims against her co-workers; and Trumann Health could not be liable for defamation because plaintiff premised Trumann Health's liability upon the individual defendants' liability. Accordingly, the court affirmed the judgment. View "Evance v. Trumann Health Services, et al." on Justia Law

Plaintiff sued the University and others under 42 U.S.C. 1983 after her employment was terminated for gross misconduct. On appeal, plaintiff challenged the district court's adverse grant of summary judgment on her due process violation and gender discrimination claims. The court concluded that, assuming plaintiff had a property interest in her continued employment, her due process claim failed because she received all of the process that she was due; regardless of whether defendants deprived plaintiff of a liberty interest in her reputation, she could not establish a due process violation because she did not sufficiently, if at all, request a name-clearing hearing; the district court did not err in finding that plaintiff failed to show direct evidence of discrimination or that defendants' explanation for terminating her was a pretext for gender discrimination. Accordingly, the court affirmed the judgment. View "Floyd-Gimon v. University of Arkansas, et al." on Justia Law

Plaintiff sued his employer under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623, and the Iowa Civil Rights Act (ICRA), Iowa Code 216.6, alleging that he was discharged from his employment due to his age. The district court granted summary judgment in favor of the employer. The court concluded that, taken together, plaintiff's evidence was sufficient to allow a rational factfinder to find that the employer's proffered reasons for terminating him were pretextual. Plaintiff's evidence was not inconsistent with a reasonable inference of age discrimination and, therefore, the court reversed the grant of summary judgment and remanded for further proceedings. View "Ridout v. JBS USA, LLC" on Justia Law