Justia Constitutional Law Opinion Summaries

Plaintiffs, television news reporters for KPIX-TV, brought suit alleging that KPIX discriminated against them on the basis of age and gender, in violation of California law, when they were laid off. The district court granted KPIX's motion for summary judgment, dismissing all of plaintiffs' claims. The court held that, although plaintiffs established a prima facie case of discrimination, they did not present sufficient evidence of pretext to survive summary judgment. The court wrote to clarify that a plaintiff could make a prima facie case of disparate-treatment age discrimination using statistical evidence, even where that evidence did not account for defendant's legitimate nondiscriminatory reason for the discharge.

Defendant appealed his jury conviction of two counts of making a false statement with respect to information required to be kept by a federally licensed firearms dealer. The court held that the district court correctly instructed the jury on the elements of the offense; the district court properly decided as a matter of law that Form 4473 was required to be kept by licensed firearm dealers; and the district court provided adequate instructions on witness credibility. Accordingly, the court affirmed the judgment.

Plaintiff sued defendants under 42 U.S.C. 1983, alleging that the copying and dissemination of her son's autopsy photographs violated her Fourteenth Amendment Due Process rights. The court held that plaintiff had a constitutionally protected right to privacy over her child's death images. But, because defendant Coulter, the San Diego Deputy District Attorney, wasn't acting under color of state law when he sent the autopsy photograph to the press, that claim must be dismissed. And, because there was no "clearly established" law to inform Coulter that any of his earlier conduct was unlawful, Coulter was entitled to qualified immunity. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendants.

After plaintiff was convicted for drug possession with intent to distribute, plaintiff sought the return of his property seized by the government during his arrest pursuant to Federal Rule of Criminal Procedure 41(g). Because some of plaintiff's belongings were inadvertently lost or destroyed, plaintiff sought equitable relief in the form of money damages to compensate for the missing property. The court affirmed the district court's grant of the government's motion to dismiss because sovereign immunity barred plaintiff's suit for money damages against the government.

Defendant appealed his sentence following his conviction of three counts of assaulting a federal correctional officer. The sentence was imposed by a judge other than the trial judge, whose unavailability for sentencing was unexplained. A judge visiting the District of Arizona imposed the sentence with insufficient familiarity with the case. Because of that unfamiliarity and the unjustified replacement of the trial judge, the sentencing violating Federal Rule of Criminal Procedure 25(b) with prejudice. Accordingly, the court vacated the sentence and remanded for sentencing by the trial judge.

Plaintiff appealed the dismissal of his pro se complaint under 42 U.S.C. 1983, against certain prison medical providers, alleging that the providers' delay in treating his hernia amounted to deliberate indifference to his medical needs, in violation of the Eighth Amendment. The court held that plaintiff voluntarily consented to the jurisdiction of any magistrate judge, including the one who decided his case; the allegations against Dr. Schuster could not support a deliberate indifference claim because they amount to a claim of negligence; and the allegations against Dr. Rotman were sufficient to warrant ordering him to file an answer. Accordingly, the court affirmed in part, reversed in part, and remanded in part.

Plaintiff, a 69-year-old inmate, appealed the grant of summary judgment denying his claims for violations of his rights under the Eighth Amendment. Plaintiff claimed that the doctors and wardens in the Nevada Department of Corrections were deliberately indifferent to his medical needs. The court held that the district court improperly concluded that there was a mere disagreement of medical opinion in this case and did not identify the triable issues of fact. Because plaintiff had not yet had his hip surgery, and may or may not be eligible for surgery, his claim for injunctive relief was not moot and should be addressed on remand. Accordingly, the court reversed in part, affirmed in part, and remanded in part.

Petitioner appealed the district court's denial of his petition for habeas corpus, brought under 28 U.S.C. 2254. Petitioner's grounds for appeal pertained to the prosecution's primary witness, a minor named R.H. Petitioner argued that the trial court violated his rights when it denied him pretrial access to R.H. and then limited cross-examination of R.H. during the trial. The court held that petitioner had no absolute right to pretrial access to R.H.; no prosecutorial inference arose when an unrelated government agency acted in R.H.'s best interests; and the trial court's limitations on the length and content of cross-examination were permissible. Accordingly, the court affirmed the judgment.

In this appeal from the denial of habeas relief, the court addressed whether petitioner's Apprendi claim was procedurally defaulted under Oregon's preservation rule. Petitioner failed to raise at the state trial court level the Apprendi claim that formed the basis of his challenge to his enhanced sentence under Oregon's "dangerous offender" law. Although petitioner raised the issue in his appeal to the Oregon Court of Appeals, that court declined to consider the merits of the claim because the issue had not been raised in the trial court and did not meet the plain error exception to the preservation rule. Petitioner ultimately sought habeas relief in federal court, but the district court concluded that the Apprendi claim was procedurally defaulted under federal law and dismissed his habeas petition. Because the court concluded that the Oregon Court of Appeals' ruling was not interwoven with federal law, the court affirmed the district court's judgment.

Defendant, a citizen and national of Mexico, was charged with drug-related crimes. At issue was whether the Confrontation Clause or the Federal Rules of Evidence prohibited the government from introducing at trial a defendant's admissions to a police officer because the translator who facilitated them, while conversationally fluent, would not qualify as a court reporter. The court held that the district court did not err in concluding that the translator, Officer Hernandez, served merely as a language conduit for defendant. Even if Officer Hernandez's translations were not properly construed as defendant's own statements, the requirements of the Confrontation Clause were satisfied by the officer's appearance at trial. The court also held that the district court did not err in refusing to instruct the jury to infer from the government's destruction of certain personal property that it would have yielded evidence harmful to the government where defendant conceded that there was no bad faith shown in this case. Finally, because the district court did not commit cumulative errors, defendant was denied relief and the judgment was affirmed.