Justia Constitutional Law Opinion Summaries

The Lands Commission appealed the district court's final judgment in this eminent domain case, wherein the United States took a fee simple interest in the property at issue on behalf of the Navy, which has continuously leased this parcel since 1949. In condemning the property, the United States sought to extinguish California's public trust rights. The court concluded that, having paid just compensation, the United States was entitled to the interest it sought in its complaint in condemnation; full fee simple, free of California's public trust. The court concluded that neither the equal-footing doctrine nor the public trust doctrine prevented the federal government from taking that interest in the land unencumbered.

This case concerned the constitutionality of certain California statutes and regulations that prohibit licensed opticians from offering prescription eyewear at the same location in which eye examinations were provided and from advertising that eyewear and eye examinations were available in the same location. Plaintiffs maintained that these statutes and regulations violated the dormant Commerce Clause. The court held that there was no material issue of fact regarding whether the challenged laws placed a significant burden on interstate commerce and therefore, the court affirmed the district court's grant of summary judgment in favor of the State.

Plaintiffs filed suit in district court under 28 U.S.C. 1332(a)(2). Plaintiffs subsequently appealed from the district court's dismissal without prejudice of their first amended complaint for lack of subject matter jurisdiction. The district court, citing Hertz Corp. v. Friend, dismissed the complaint because plaintiffs failed to provide factual support for their allegations of diversity. But Hertz did not impose a heightened pleading standard and, in two orders issued before its order of dismissal, the district court requested that plaintiffs provide further allegations of the corporate parties' principal place of business, not further proof. The district court did not abuse its discretion by requesting proof of the parties' principal places of business, but the court found that the district court's order was inconsistent. Accordingly, the court vacated the order and dismissed the first amended complaint, and remanded.

Defendant appealed his conviction for social security fraud pursuant to 42 U.S.C. 408(a)(5). The court held that the district court committed no reversible error in the formulation of jury instructions; the district court acted within its discretion when it admitted computer-generated records into evidence; the prosecutor's comments did not warrant reversal of defendant's conviction; the district court committed no error when it denied defendant's motion for judgment of acquittal; and 42 U.S.C. 408(a)(5) was not unconstitutionally vague. Accordingly, the court affirmed the judgment.

Plaintiffs filed a complaint in federal district court against the United States government, alleging causes of action under the Federal Tort Claims Act (FTCA), 28 U.S.C. 2671-2680. Specifically, plaintiffs alleged that agents from the DEA committed the torts of assault and battery and intentional infliction of emotional distress when they executed a search warrant at plaintiffs' mobile home. The court agreed with the district court that there was no genuine issue of material fact regarding whether DEA Agents' use of force against the adult members of plaintiffs' family was reasonable. The court, however, disagreed with the district court's conclusion that there was no genuine issue of material fact regarding whether DEA Agents used reasonable force against the 11-year-old and 14-year-old plaintiffs. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings.

Plaintiff alleged that defendants' determination, that plaintiff's psychological disorder made her unfit for reinstatement from disability retirement to active service with the Caltrans, deprived her of her right to a reasonable accommodation under the Americans with Disabilities Act (ADA), 42 U.S.C. 12111-12117. At issue was whether a state employee could sue state officers under 42 U.S.C. 1983 for alleged violations of Title I of the ADA. The court concluded that Congress' inclusion of a comprehensive remedial scheme in Title I precluded section 1983 claims predicated on alleged violations of the ADA Title I substantive rights. The court also concluded that plaintiff's allegations of fact did not state a claim under the Equal Protection Clause.

These cross-appeals arose from what the court understood to be the largest civil in rem forfeiture proceeding against firearms unlawfully possessed by a convicted felon in American history. The court addressed several issues, holding that Maria Ferro was not entitled to the protections of the so-called "innocent owner" defense, and the district court was therefore correct to hold that the entire collection was subject to forfeiture; following a comprehensive revision of the forfeiture statutes in 2000, forfeitures of instrumentalities of crimes were subject to excessiveness analysis under the Eighth Amendment's Excessive Fines Clause; excessiveness review must consider the individualized culpability of the property's owner and, when analyzing the offending conduct, it must focus only on the conduct that actually gave rise to the forfeiture of the property at issue, not other criminal conduct by the same person; and because the district court erred on this third point, the court remanded for the district court to undertake once again the excessiveness inquiry.

Defendant was convicted for being a felon in possession of a firearm. At issue was whether the basis of the search that resulted in defendant's conviction was so attenuated as to require suppression of the firearms evidence found in the search. The district court held that there was a lack of probable cause to issue the warrant authorizing the search, but invoked the good faith reliance doctrine of United States v. Leon to permit use of the evidence. The court held that the warrant to search defendant's home did not issue upon probable cause. The underlying affidavit simply did not establish a "fair probability" that the gun and ammunition associated with the homicide would be found there, or even provide a "colorable argument for probable cause." Therefore, Leon's good faith exception to the officers' execution of the warrant did not apply either. Accordingly, the court reversed and remanded for further proceedings.

A coalition of media corporations filed this action under 42 U.S.C. 1983 shortly after the issuance of the warrant for Richard Leavitt. Plaintiffs asserted that, as surrogates for the public, they had a right to witness all stages of the executions conducted by the State of Idaho, rather than just the final portion, and that the State's refusal to allow such access violated the First Amendment. The court concluded that the State has had ample opportunity to adopt an execution procedure that reflected settled law, whereby the public had a First Amendment right to view executions from the moment the condemned was escorted into the execution chamber, including those initial procedures that were inextricably intertwined with the process of putting the condemned inmate to death. The State had nonetheless failed to bring its procedure into compliance with the law. Therefore, the court reversed the district court's denial of a preliminary injunction and remanded for the entry of an injunction forthwith, and in any event prior to the impending execution of Leavitt.

In Case No. 12-35450, petitioner sought relief under FRCP 60(b), claiming that Martinez v. Ryan rendered him eligible to pursue ineffective assistance of counsel claims on which he had ostensibly defaulted. In Case No. 12-35427, petitioner petitioned the district court to order the police department to send evidence related to his crime to a lab for forensic testing. The court held that petitioner failed to meet his burden under Strickland in proving that counsel's performance was both deficient and prejudicial. In regards to the forensic testing, the court held that petitioner had not shown good cause for such a discovery request where he had not explained how the testing that he sought would substantiate his underlying claim that his trial counsel was ineffective. Accordingly, the court affirmed the judgment.