Justia Constitutional Law Opinion Summaries

This appeal arose when the People of California adopted Proposition 8, which amended the state constitution to eliminate the right of same-sex couples to marry. At issue was whether this amendment violated the Fourteenth Amendment to the United States Constitution. The court declined to address the more general questions presented to it concerning the rights of same-sex couples to marry. The court concluded that, through the proponents of ballot measures, the People of California must be allowed to defend in federal courts, including on appeal, the validity of their use of the initiative power. Accordingly, the proponents possessed Article III standing to prosecute this appeal from the district court's judgment invalidating Proposition 8. However, the court concluded that the People could not employ the initiative power to single out a disfavored group for unequal treatment and strip them, without a legitimate justification, of a right as important as the right to marry. By using their initiative power to target a minority group and withdraw a right that it possessed, without legitimate reasons for doing so, the People violated the Equal Protection Clause. Therefore, the court held that Proposition 8 was unconstitutional on this ground and affirmed the judgment of the district court. The court also affirmed the denial of the motion by the official sponsors of Proposition 8 to vacate the judgment entered by former Chief Judge Walker, on the basis of his purported interest in being allowed to marry his same-sex partner.

Defendant appealed his conviction for being a deported alien found in the United States without permission. Defendant contended that the district court should have granted his motion to dismiss the indictment because it was based on a 2001 removal order that was entered in violation of his due process right to counsel, prejudicing his ability to obtain immigration relief. The court concluded that defendant did not waive his right to counsel and was denied his due process right to counsel because he was not properly advised of his rights in a language that he could understand. The court held, however, that this violation of his right to counsel was not inherently prejudicial. Because defendant could not demonstrate that he had a plausible claim to relief in 2001, he was not actually prejudiced as a result of the due process violations in his removal proceedings. Accordingly, entry of the 2001 removal order was not fundamentally unfair.

This case concerned California's adoption of an initiative constitutional amendment to prohibit same-sex marriage. At issue was whether the district court abused its discretion by ordering the unsealing of the video recording of the trial, which had purportedly been prepared by the trial judge for his in-chambers use only and was later placed in the record and sealed by him. The order, issued by his successor following his retirement, would permit the broadcast of the recording for all to view. The court concluded that the district court abused its discretion by ordering the unsealing of the recording of the trial notwithstanding the trial judge's commitment to the parties that the recording would not be publicly broadcasted. The district court further abused its discretion by holding that the determinations made by the trial judge regarding the placement of the recording under seal did not bind a different judge presented with a motion to unseal - a conclusion the court regarded as an "implausible" and "illogical" application of the law. Therefore, the court reversed the order of the district court and remanded with instructions to maintain the recording under seal.

Plaintiffs sued Roommate.com in federal court, alleging that the website's questions requiring disclosure of sex, sexual orientation and familial status, and its sorting, steering and matching of users based on those characteristics violated the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., and the California Fair Employment and Housing Act (FEHA), Cal. Gov't Code 12955. Because precluding individuals from selecting roommates based on their sex, sexual orientation and familial status raised substantial constitutional concerns, the court interpreted the FHA and the FEHA as not applying to the shared living units. Therefore, the court held that Roommate.com's prompting, sorting and publishing of information to facilitate roommate selection was not forbidden by the FHA or the FEHA. Accordingly, the court vacated the district court's judgment and remanded for entry of judgment for defendant. Because plaintiffs were no longer prevailing, the court vacated the district court's order for attorney's fees and dismissed the cross-appeal on attorney's fees as moot.

Defendant appealed his convictions related to an alien smuggling organization, challenging the sufficiency of the evidence on two grounds. First, he argued that there was insufficient evidence of alienage with respect to the ten material witnesses named in the indictment who did not testify at trial. Second, as to his conviction for aiding and abetting the bringing of illegal aliens to the United States for financial gain, he contended that there was insufficient evidence linking him to the cross-border transportation of the named material witnesses before they were dropped in the United States, as required by United States v. Lopez. The court held that the jury could reasonably find that defendant rented properties knowing they would be used as load houses long before the named material witnesses were brought across the border. The court also held that defendant knowingly and intentionally aided in bringing about the smuggling of the named material witnesses into the United States. Therefore, a reasonable jury could find sufficient "specific evidence" linking defendant to "intentionally aiding...the cross-border transportation" of the named material witnesses prior to when they were dropped off in the United States. Accordingly, the judgment was affirmed.

Plaintiff, a minor, brought federal civil rights claims under 42 U.S.C. 1983 and state negligence claims against the County and its employee social workers (collectively, defendants). Plaintiff, sexually assaulted by his 17-year-old foster brother while living in a foster family home, contended that defendants failed to intervene prior to his sexual assault, despite their knowledge of the escalating threats and violence against him. The district court dismissed with prejudice all claims against the County. The court concluded that the district court abused its discretion because the district court denied leave to amend where plaintiff was denied the opportunity to allege additional facts supporting the claim that defendant's constitutional violations were carried out pursuant to County policy or custom and where the County's derivative liability was tied directly to the negligence of, or successful assertion of immunity by, its employees. Accordingly, the court reversed the district court's decision and vacated the judgment.

Defendant, a former state prison guard, appealed his conviction and sentence stemming from his assault on two inmates. The court previously reversed the district court's grant of a judgment of acquittal following the jury's verdict. On appeal, defendant contended that the district court erred in failing to conditionally rule that he was entitled to a new trial if the judgment of acquittal were to be reversed, and that he was deprived of the effective assistance of counsel when his trial counsel failed to make a new trial motion. The court held that the district court did not err in failing to make a conditional new trial ruling at the time it granted defendant's motion for acquittal; the court could not determine whether defendant's counsel was constitutionally deficient in failing to request such a ruling; defendant's conviction was therefore affirmed without prejudice to his filing a claim for ineffective assistance of counsel in an 28 U.S.C. 2255 proceeding; defendant's right to due process was violated when the district court relied on unreliable, unsubstantiated allegations in imposing his sentence; and defendant's sentence was vacated and remanded for further proceedings before a district judge who had not previously presided over the case.

In this interlocutory appeal, defendant challenged an order denying his motion to quash a subpoena in a 28 U.S.C. 2255 habeas proceeding brought by his wife. Defendant and his wife were convicted in separate trials for fraud arising from an insurance scam involving the wife's car. The wife subsequently alleged that her counsel provided ineffective assistance by failing to call defendant as a witness. Defendant intervened to seek quashal of the subpoenas directed at counsel on the basis of a joint defense privilege. The court remanded to the district court for an in camera evidentiary hearing to determine if and when the joint defense agreement ended, and when the communication at issue here (what defendant would ultimately testify at his wife's trial) was made. Accordingly, the court reversed and remanded the judgment.

Three juvenile defendants, each of whom was a member of an Indian Tribe and who pleaded true to a charge of aggravated sexual abuse with children, appealed their conditions of probation or supervision requiring registration under the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16901, et seq. Defendants argued that SORNA's registration requirement contravened the confidentiality provisions of the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031 et seq., and also challenged its constitutionality. The court held that because Congress, in enacting SORNA, intentionally carved out a class of juveniles from the FJDA's confidentiality provisions, and that SORNA's registration requirement was constitutionally sound, the district court's imposition of the sex offender registration conditions was constitutionally sound.

A juvenile male appealed the district court's determination that he was an "Indian" under 18 U.S.C. 1153, which provided federal criminal jurisdiction for certain crimes committed by Indians in Indian country. The juvenile claimed that he did not identify as an Indian, and was not socially recognized as Indian by other tribal members. Nonetheless, he was an enrolled tribal member, had received tribal assistance, and had used his membership to obtain tribal benefits. Therefore, because the juvenile was Indian by blood and easily met three of the most important factors used to evaluate tribal recognition laid out in United States v. Bruce, the court held that he was an "Indian" under section 1153 and upheld his conviction.