Justia Constitutional Law Opinion Summaries

Plaintiff appealed the district court's grant of summary judgment in favor of defendants. Plaintiff alleged that defendants violated the Help America Vote Act of 2002 (HAVA), 42 U.S.C. 15301-15545, by failing to conduct a general election recount, in which plaintiff lost, in accordance with HAVA provisions. Because HAVA section 301 was not intended to benefit voters and candidates in local elections with respect to recounts, such individuals did not have a private right of action under 42 U.S.C. 1983. Therefore, the court affirmed the district court's dismissal of plaintiff's claims for failure to state a claim.

Plaintiff appealed the district court's dismissal of claims he brought against Board Members, in their individual capacities, under 42 U.S.C. 1983. Plaintiff alleged that the Board Members deprived him of his constitutional rights when, in an ex parte emergency proceeding, they summarily suspended his authority to prescribe medication. The court held that the Board Members were absolutely immune from plaintiff's claims for money damages where they were functionally comparable to judges and their summary suspension authority was comparable to a judicial act. The court also held that Younger abstention barred plaintiff's claims for equitable relief. Accordingly, the court affirmed the judgment.

Petitioner, a California state prisoner, appealed the district court's order denying his petition for a writ of habeas corpus. Petitioner claimed that testimony introduced during his trial violated his Sixth Amendment right to confrontation. In light of the extensive, reasoned disagreement between the lower courts as to the question presented by petitioner's claim - whether forensic lab reports were testimonial - and between the Justices when they reached the issue, the court could not say that the state unreasonably applied clearly established Federal law. The court concluded that the state court probably committed constitutional error, but the court was not free to correct it under the Antiterrorism and Effective Death Penalty Act of 1996, 28 U.S.C. 2254(d). The error could have been brought before the Supreme Court in a correctable posture, had petitioner filed a cert petition after the California Supreme Court denied review in 2005. The case would have arrived at the Court nearly two years before Melendez-Diaz v. Massachusetts, and it was possible that the Court would have granted cert and decided on petitioner's case that forensic lab reports were testimonial. The Court did not decide until 2011, in Bullcoming v. New Mexico, that the right to confrontation could be satisfied only by the live testimony of a declarant.

Petitioner, a prisoner of the State of California, appealed from the denial of his petition for a writ of habeas corpus. The court remanded to the district court to determine in the first instance whether, under California law, petitioner filed his petition in the court of appeals within a reasonable time after the denial of his first petition in the superior court. In determining whether, under the circumstances of the case, California law would excuse petitioner's delay, the district court should consider all relevant factors.

Defendant was sentenced to a 17-year prison term pursuant to a plea agreement. Two years later, defendant filed a motion to reduce his sentence under 18 U.S.C. 3582(c)(2), which the district court granted. While this case was pending, the United States Supreme Court decided Freeman v. United States. The court concluded that Justice Sotomayor's concurrence in Freeman controlled this case because defendant's plea agreement was a Federal Rule of Criminal Procedure 11(c)(1)(C) plea agreement. Applying her opinion, the court held that the district court lacked jurisdiction to reduce defendant's sentence because the imposed 17-year sentence was "based on" the parties' plea agreement and not on "a sentencing range that has subsequently been lowered by the Sentencing Commission."

Petitioner appealed the district court's denial of his petition for a writ of habeas corpus, claiming that the district court incorrectly interpreted an earlier ruling by the California Supreme Court on one of his state habeas petitions. At issue was whether, when the the California Supreme Court denied a habeas petition with citations to Ex parte Swain, the denial was necessarily based on untimeliness. The court agreed with petitioner that the answer was no and that the district court did not correctly apply California law in determining that the California Supreme Court's denial of his petition with citation to Swain and People v. Duvall meant that petitioner's petition before the California Supreme Court was untimely. Because the federal statute of limitations was tolled during the pendency of timely filed state petitions, petitioner's federal petition was therefore timely, and the court reversed and remanded to the district court to consider the petition on the merits.

This case stemmed from a class action that began more than a quarter century ago where Idaho state prisoners at the Idaho State Correctional Institution (ISCI) prevailed on their claims that, inter alia, because of deliberate indifference, without any connection to a legitimate penological purpose, the inmates were subjected to needless pain and suffering on account of inadequate medical and psychiatric care. The district court issued an injunction to remedy the constitutional violations and the injunctions remained in effect in 2008 and 2009 when the facts giving rise to this case occurred. The Portland law firm of Stoel Rives, LLP was appointed to represent the prisoner class. At issue on appeal was whether Stoel Rives was entitled to an attorneys' fee award in the class action under the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e. The court held that, in this case, the judge had discretion to consider whether Stoel Rives's work on a motion to compel conformity to the injunction was "directly and reasonably incurred in enforcing the relief." The district court acted within the bounds of its discretion in awarding fees in a reasonable amount for bringing about that conformity with the injunction. Here, Stoel Rives's work was what one would expect of a lawyer working for a client that could afford its efforts but that was not indifferent to the cost. The firm showed no evidence of milking the case, and the fees were "directly and reasonably incurred." Accordingly, the court affirmed the judgment.

Proposition 200, Ariz. Rev. Stat. 16-166(F)(the registration provision), required prospective voters in Arizona to provide proof of U.S. citizenship in order to register to vote and required registered voters to show identification to cast a ballot at the polls, Ariz. Rev. Stat. 16-579(A)(the poll place provision). At issue on appeal was whether Proposition 200 violated section 2 of the Voting Rights Act of 1965 (VRA), 42 U.S.C. 1973, was unconstitutional under the Fourteenth Amendment or Twenty-fourth Amendment to the Constitution, or was void as inconsistent with the National Voter Registration Act of 1993 (NVRA), 42 U.S.C. 1973gg et seq. The court upheld Proposition 200's requirement that voters show identification at the polling place, but concluded that the NVRA superseded Proposition 200's registration provision as that provision was applied to applicants using the National Mail Voter Registration Form to register to vote in federal elections.

Defendant pled guilty to Abusive Sexual Contact where the victim was his wife's minor niece who had been staying with the couple. On appeal, defendant appealed his sentence of 151 months' imprisonment and the imposition of a two-level enhancement pursuant to U.S.S.G. 2A3.1(b)(3), claiming that he was not entrusted with custody, care, or supervisory control of the victim. The court held that the district court's application of the enhancement was fully supported and that court did not err in applying the enhancement in this case.

Defendants, two priests, an eighty-year-old nun, and two grandmothers, were longtime peace and disarmament activists who cut their way through two fences into a secure area of a naval base. Defendants were subsequently convicted of charges related to their acts of symbolic protest, on the naval base, against nuclear weapons. On appeal, defendants challenged the district court's refusal to dismiss the indictment. The court affirmed the convictions and held that the Hague Convention neither conflicted with nor superseded 18 U.S.C. 1361, 1363, and 1382 and the district court properly refused to dismiss the indictment. The court also held that the jury instructions accurately presented the law to the jury and that a jury could easily have found beyond a reasonable doubt that defendants cut the fences intending to destroy or injure them under 18 U.S.C. 1363. Accordingly, the court affirmed the judgment.