Justia Constitutional Law Opinion Summaries

Defendant was convicted of five counts relating to child pornography and subsequently appealed his convictions. The court held that the district court did not err in denying defendant's untimely motion to proceed pro se and, moreover, defendant failed to make an unequivocal request to proceed pro se. The court also held that the district court did not err in denying defendant's motion to dismiss as barred by the statute of limitations the first two counts against him where the district court applied 18 U.S.C. 3283's extended statute of limitations. Accordingly, the court affirmed the judgment.

Plaintiff appealed from the district court's orders granting full satisfactions of judgment as to defendants. Defendants were found to have violated plaintiff's civil rights and held liable for damages under 42 U.S.C. 1983 for alleged violations of his constitutional rights while he was held in pretrial detention in a Los Angeles jail in 1998. The court held that defendants' failure in the first appeal to challenge the district court's order that defendants were each jointly and severally liable for the fee award waived their ability to challenge that order subsequently. Therefore, the court vacated the satisfactions of judgment.

Plaintiffs, severely disabled California residents, alleged that conventional medical services, drugs, and medications have not alleviated the pain caused by their impairments. Therefore, each plaintiff has obtained a recommendation from a medical doctor to use marijuana to treat her pain. Plaintiffs obtained medical marijuana through collectives located in Costa Mesa and Lake Forest, California. These cities, however, have taken steps to close marijuana dispensing facilities operating within their boundaries. Plaintiffs brought an action in federal district court, alleging that the cities' actions violated Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court held that Congress has made clear that the ADA defined "illegal drug use" by reference to federal, rather than state law, and federal law did not authorize plaintiffs medical marijuana use. Therefore, the court concluded that plaintiffs' medical marijuana use was not protected by the ADA.

Petitioner filed a petition for writ of habeas corpus in federal court, raising 21 claims of relief. At issue was whether a criminal defendant's request for legal counsel to file a post-verdict motion for a new trial was a "critical stage," and whether denying such a request, because defendant previously waived his right to counsel, was a violation of clearly established federal law. The court held that defendant's Sixth Amendment right to counsel was violated when the trial court denied his timely request for representation for a new trial motion based on the notion that once waived, the right to counsel could not be reasserted. This holding was consistent with the court's previous rulings, as well as those of numerous federal circuit courts applying clearly established Supreme Court precedent. Further, due to the fundamental importance of the right to counsel, defendant need not prove prejudice and a harmless error analysis was not required. Therefore, the court reversed and remanded.

Defendant appealed the district court's denial of his motion to suppress the cocaine found in his vehicle. The court held that the district court erred when it held that the search was valid under the automobile exception to the Fourth Amendment's warrant requirement. The court also held that the impoundment of the vehicle was not justified by the community caretaking exception to the Fourth Amendment's warrant requirement. Accordingly, the court reversed and remanded for further proceedings.

Arizona death-row inmates brought this action under 42 U.S.C. 1983, asserting that the Arizona Department of Corrections' (ADC) execution protocol violated the Eighth Amendment. Lopez, one of the named plaintiffs with an impending execution date, moved the district court for a preliminary injunction against the ADC's use of its current lethal injection protocol. The district court denied relief and Lopez appealed. The court held that the district court did not abuse its discretion in denying the injunction and that Lopez's emergency motion for a stay of execution was denied for the same reason. Accordingly, the court affirmed the judgment and denied the motion for stay of execution.

Petitioner sought review for the second time of his petition for habeas relief in federal court. Petitioner asserted that his trial counsel at sentencing was ineffective and for the first time, that his postconviction relief (PCR) counsel was ineffective in his presentation of that claim. The court concluded that the district court did not abuse its discretion in denying the Rule 60(b) motion. Further, Martinez v. Ryan required petitioner to show that the defaulted claim was a substantial one. Because petitioner had not done so, the court concluded, in the alternative, that he failed to meet the necessary threshold under Martinez.

Plaintiff, on behalf of her son, sued defendants, including the school district, alleging 20 procedural and substantive violations of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The district court disposed of almost all of plaintiff's claims and plaintiff and defendants subsequently appealed. The court agreed with the school district that the district court erred by inferring from the IDEA a private right of action for nominal damages. The court also held that Congress has not expressed an intent to create a cause of action for monetary damages based on the Rehabilitation Act, 29 U.S.C. 701 et seq., and the Americans with Disabilities Act, 42 U.S.C. 12101 et seq. The court reviewed plaintiff's other contentions in her cross-appeal and find them either waived or lacking merit.

Petitioner appealed the district court's denial of his 28 U.S.C. 2254 habeas corpus petition. Petitioner argued that trial counsel's advice regarding his guilty plea was constitutionally inadequate, thereby rendering his plea unknowing or involuntary. Petitioner also sought a limited remand under the Supreme Court's recent decision in Martinez v. Ryan, to allow the district court to review the merits of two new claims for ineffective assistance of trail counsel that he raised for the first time in his federal habeas petition, but that the district court ruled was procedurally defaulted. The court concluded that the advice provided by trial counsel with regard to the guilty plea was constitutionally adequate and petitioner's plea was knowing and voluntary as a result. Petitioner knew at the time he pled guilty that it was possible the sentences would run consecutively. The court denied petitioner's Motion for a Limited Remand because the court's reading of Coleman v. Thompson, in conjunction with Martinez, lead the court to the conclusion that, in light of the extensive record before it regarding the two new claims for ineffective assistance of counsel, petitioner could not meet the "narrow circumstances" exception recognized in Martinez to show "cause and prejudice." Consequently, petitioner failed to overcome the procedural bar in Coleman.

Defendant appealed from his conviction and sentence (1) for conspiring to manufacture and distribute more than 1,000 plants of marijuana and (2) for manufacturing and cultivating, and aiding and abetting the cultivation of more than 1,000 plants. Defendant raised several issues on appeal: the district court erred by allowing a law enforcement agent to testify regarding statements defendant made through an interpreter during a post-arrest interview; the district court erred in admitting testimony regarding the number of marijuana plants found at the property where he was arrested; the district court erred at sentencing in finding that defendant had not truthfully provided all the information in his possession to the government, thereby resulting in the denial of safety valve relief; and cumulative error resulted in unfair trial. The court addressed each of defendant's claims and ultimately affirmed the conviction and sentence.