Justia Constitutional Law Opinion Summaries

Defendant was serving the final month of a 26-month term of supervised release when he was arrested for drunk driving, a violation of the conditions of his supervised release. Defendant appealed the denial of his motion to dismiss the government's petition to revoke supervised release, asserting that the district court lacked jurisdiction to revoke his supervised release. The court held that a summons based on a petition to revoke supervised release was valid to extend jurisdiction under 18 U.S.C. 3583(i) when it was signed and issued by a clerk at the discretion of a judge. Accordingly, the court affirmed the judgment.

The Warden appealed from the district court's grant of a writ of habeas corpus to petitioner. The California Supreme Court held that petitioner received constitutionally ineffective assistance of counsel at his trial but that trial counsel's deficient assistance did not prejudice petitioner. The district court disagreed with the latter conclusion, holding that petitioner had established prejudice, and granted the writ. The court found that the case against petitioner was not overwhelmingly strong; the prosecution presented circumstantial evidence only; and the defense offered an alternative version of the murders. Therefore, the case was close and a reasonable jury would have struggled with whether the theory of the alternative credible killer created a reasonable doubt as to petitioner's guilt. Thus, with the additional testimony that the state court found should have been located by counsel, there was a reasonable probability that the jury would have acquitted petitioner. Accordingly, the court agreed with the district court that petitioner had established prejudice and affirmed the judgment.

Plaintiff brought suit under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., alleging that the surviving spouse benefit provided by the city to its retired employees discriminated on the basis of sex. Plaintiff's theory of liability was that because, in the aggregate, the city paid a larger amount of money to the married retirees who selected the surviving spouse benefits than it did to single retirees who did the same, and male retirees were more likely to be married, the surviving spouse benefit had an unlawful disparate impact on female retirees. The court affirmed the district court's dismissal of plaintiff's disparate treatment claim because she failed to allege intentional discrimination and affirmed the dismissal of plaintiff's disparate impact claim because, even assuming she had Article III stand, her claim failed as a matter of law.

Defendant, a city police officer, appealed from the denial of qualified immunity in plaintiff's 42 U.S.C. 1983 action alleging First Amendment retaliation. The district court held that it was clearly established in December 2008 that a supervisor could not retaliate against a public employee for his or her subpoenaed deposition testimony offered as a citizen in the context of a civil rights lawsuit. The court agreed and affirmed the district court's denial of summary judgment on the basis of qualified immunity.

Defendant was convicted for charges related to armed bank robbery. At issue was whether, under the Mandatory Victims Restitution Act of 1996 (MVRA), 18 U.S.C. 3664(f)(2), a district court impermissibly delegated its obligation to set a restitution payment schedule when it ordered "immediate" payment with the expectation that the Bureau of Prisons (BOP) would work out a payment schedule with the prisoner pursuant to the Inmate Financial Responsibility Program (IFRP). The court held that where the sentencing court has failed to consider whether defendant had the financial resources to pay restitution immediately, ordering immediate payment impermissibly delegated to the BOP the court's obligation to set a payment schedule.

Plaintiffs, a group of foster children, appealed the dismissal of their complaint pursuant to Rule 12(b)(6). Plaintiffs brought this action under 42 U.S.C. 1983, alleging violations of their substantive and due process rights under the Fourteenth Amendment and violations of their statutory rights under the Adoption Assistance and Child Welfare Act (CWA), 42 U.S.C. 670 et seq.; the Child Abuse Prevention and Treatment Act (CAPTA), 42 U.S.C. 5101 et seq.; and the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1431 et seq. The complaint alleged that the county's foster care system was plagued by systemic failures that resulted in violations of the rights guaranteed to foster children by federal statutes and the Due Process clause of the Fourteenth Amendment. The court reversed the dismissal of Counts One, Two, Three, Eight, and Eleven; affirmed the dismissal of Counts Nine and Ten; and remanded for further proceedings. On remand, the district court should allow plaintiffs leave to amend their substantive due process claims, and plaintiffs could seek further leave to amend if they wished to add a claim under the IDEA's express cause of action.

Petitioner, a California state prisoner, appealed the district court's holding that his 28 U.S.C. 2254 habeas corpus petition was time-barred by the one-year statute of limitations created by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). Petitioner argued that he was entitled to equitable tolling for the entire time he pursued his state habeas petitions because, in deciding when he should file his federal habeas petition, he was entitled to rely on then-existing Ninth Circuit precedent under which his federal habeas petition would have been timely when filed. The court agreed, holding that a habeas petitioner who decided when to file his petition in accord with Ninth Circuit precedent that was later overturned by the Supreme Court was entitled to equitable tolling. Accordingly, the court vacated the district court's order and remanded the case to the district court for consideration of the petition on the merits.

Petitioner appealed the district court's denial of his federal petition for a writ of habeas corpus. Petitioner raised three claims on appeal: (1) petitioner challenged the California Court of Appeal's conclusion that his waiver of his Sixth amendment right to a jury trial was valid; (2) petitioner claimed that the California court erred in finding that the trial court acted within its discretion to deny his subsequent attempt to withdraw the jury trial waiver; and (3) petitioner contended that the California court erred in finding that his sentence of 26 months to life under California's Three Strikes Law did not constitute cruel and unusual punishment under the Eighth Amendment. Because the court concluded that these holdings of the California Court of Appeal were neither contrary to, nor involved an unreasonable application of, clearly established Federal law, the court affirmed the district court's denial of the petition.

After the September 11, 2011 attacks, the government detained plaintiff, an American citizen, as an enemy combatant. Plaintiff alleged that he was held incommunicado in military detention, subjected to coercive interrogation techniques and detained under harsh conditions of confinement, all in violation of his constitutional and statutory rights. Plaintiff and his mother sued John Yoo, the Deputy Assistant Attorney General in the U.S. Department of Justice's Office of Legal Counsel (OLC) from 2001 to 2003, alleging that they suffered from plaintiff's unlawful detention. The court held that, under recent Supreme Court law, Ashcroft v. al-Kidd, the court was compelled to conclude that, regardless of the legality of plaintiff's detention and the wisdom of Yoo's judgments, at the time he acted the law was not "sufficiently clear that every reasonable official would have understood that what he [wa]s doing violated[d]" plaintiff's rights. Therefore, the court held that Yoo must be granted qualified immunity and accordingly reversed the decision of the district court.

Defendant pleaded guilty to one count of conspiracy to traffic in motor vehicles or motor vehicle parts, two counts of operating a chop shop, and seventeen counts of trafficking in motor vehicles. The jury then convicted defendant of two related crimes: one count of witness tampering and one count of discharging a firearm during and in relation to a crime of violence. Defendant subsequently appealed from the judgment and sentence on all counts. The court held that the district court did not abuse its discretion in admitting the two witness' testimony about seeing defendant with a Glock or similar gun before the shooting; the prosecutor did not improperly vouch for a witness' credibility; because the detective's remark, though improper, did not prejudice defendant, the district court did not abuse its discretion in denying defendant's motions for mistrial and new trial; and because the sentencing range of defendant's 18 U.S.C. 924(c)(1)(A) conviction was ten years to life, the district court permissibly sentenced him to an 18-year term of imprisonment on Count 22. Accordingly, the judgment was affirmed.