Justia Constitutional Law Opinion Summaries

Defendant filed a due process hearing complaint with California's Office of Administrative Hearings (OAH), alleging that he was being denied the free appropriate public education (FAPE) that he was entitled to under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court certified the following question to the California Supreme Court: Does California Education Code 56041 - which provided generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for providing special education services - apply to children who are incarcerated in county jails? The case was withdrawn from submission and further proceedings were stayed pending final action by the Supreme Court of California.

Plaintiff, a former inmate in the ODOC, sued several ODOC officials in their official capacity, alleging, among other things, that they were substantially burdening plaintiff's practice of his Native American religion in violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc to 2000cc-5. At issue was what relief was available to plaintiff. The court concluded that money damages were not available under RLUIPA against state officials sued in their official capacity. Because the ODOC had released plaintiff from its custody, his claims for declaratory and injunctive relief were moot. Therefore, the court affirmed the district court's dismissal of plaintiff's claims.

The district court granted a preliminary injunction prohibiting the State of Washington from enforcing its limitation on contributions to political committees supporting the recall of a state or county official. The court concluded that plaintiffs satisfied their burden under Winter v. Natural Resources Defense Council, Inc., to demonstrate that the contribution limit was likely an unconstitutional and harmful burden on plaintiffs' rights of free speech under the First Amendment. Accordingly, the district court did not err in granting the injunction and the court affirmed the judgment.

Defendant was arrested during a DEA "buy bust" operation and subsequently convicted of possession with intent to distribute 500 or more grams of a substance containing methamphetamine and conspiracy to distribute 500 or more grams of a substance containing methamphetamine. Defendant appealed his conviction. The court held that even if the trial court's failure to administer oaths to a government informant's interpreters was plain error, the error did not affect defendant's substantial rights. The court also held that the district court did not plainly err in admitting the nontestifying agents' statements and there was sufficient evidence to sustain the verdict. Because defendant had not identified any other error, there was no cumulative error wanting reversal.

This case concerned the Washington State Grange's proposed People's Choice Initiative of 2004, or Initiative 872. I-872 created a "top two" primary in which the primary served as a means of winnowing the candidates to two rather than selecting party nominees. At issue was whether the State of Washington had designed its election ballots in a manner that eliminated the risk of widespread voter confusion, a question left unresolved in Washington State Grange v. Washington State Republican Party. The court held that the state had done so. The ballots, and related informational material, informed voters that, although each candidate for partisan office could specify a political party that he or she preferred, a candidate's preference did not imply that the candidate was nominated or endorsed by the party, or that the party approved of or associated with that candidate. Given the design of the ballot, and in the absence of evidence of actual voter confusion, the court held that Washington's top primary system, as implemented by the state, did not violate the First Amendment associational rights of the state's political parties. The court also affirmed the district court's dismissal of plaintiffs' ballot access and trademark claims. The court reversed the district court's order granting the state's request for reimbursement of attorney's fees paid in accordance with a 2006 stipulation.

Defendant, a citizen of Macau, engaged in efforts to import protected defense articles from the United States into China, without the licenses required by law. Defendant was convicted after a jury trial on four counts of conspiracy and attempt to export defense articles without a license, money laundering, and conspiracy and attempt to smuggle goods from the United States. Defendant challenged his conviction and sentence. The court concluded that venue was proper in the Southern District of California; disagreed with defendant that the Arms Export Control Act, 22 U.S.C. 2778, violated the nondelegation principle; concluded that defendant's conviction on count three must be vacated as a matter of law because attempting to cause an export of a defense article was not a federal crime; defendant's conviction on count four must also be vacated for lack of jurisdiction; and because the district court should have allowed defendant to present evidence of duress to the jury, the court reversed and remanded for a new trial on counts one and two. The court did not reach defendant's arguments regarding his sentence.

After her first termination from the City of Pasadena Police Department and subsequent reinstatement, plaintiff brought a lawsuit in state court claiming that she had been discriminated against and harassed by the City due to its perception that she had a disability. After her second termination, she reinstated her discrimination and harassment claims in an administrative proceeding, where she also argued that the termination was retaliatory. Both of plaintiff's actions resulted in a decision in favor of the City. Plaintiff subsequently brought claims in federal court based on the same theories in state proceedings. The court held that California principles of issue preclusion prevented the court from reaching these issues.

Plaintiffs, Washington Medicaid beneficiaries with severe mental and physical disabilities, appealed the district court's denial of their motion for a preliminary injunction. Plaintiffs sought to enjoin the operation of a regulation promulgated by Washington's DSHS that reduced the amount of in-home "personal care services" available under the state's Medicaid plan. The court concluded that plaintiffs have demonstrated a likelihood of irreparable injury because they have shown that reduced access to personal care services would place them at serious risk of institutionalization. The court further concluded that plaintiffs have raised serious questions going to the merits of their Americans with Disabilities Act, 42 U.S.C. 12132, and Rehabilitation Act, 29 U.S.C. 794(a), claims, that the balance of hardships tipped sharply in their favor, and that a preliminary injunction would serve the public interest. Accordingly, the court remanded for entry of a preliminary injunction.

Defendant and a group of allegedly similarly situated state prisoners brought suit under 42 U.S.C. 1983 against defendants, alleging that they were overdetained in violation of federal and state law. At issue was whether state prison officials had a clearly established duty to seek out original court records in response to a prisoner's unsupported assertion that he was being overdetained in violation of the United States Constitution. The court held that there was no clearly established duty on a prison official to review a prisoner's original court records beyond those in his institutional file on the facts of this case. Thus, defendants were entitled to qualified immunity.

Three nonresidents of California brought a would-be class action against Oracle seeking damages under California law for failure to pay overtime. Plaintiffs' first two claims were based on work performed in California. The third claim was based on work performed anywhere in the United States. The district court granted summary judgment to Oracle on all three claims, on the ground that the relevant provisions of California law did not, or could not, apply to the work performed by plaintiffs. After certifying several questions of state law to the California Supreme Court and receiving answers from that court, the court reversed summary judgment on the first two claims and affirmed the third claim. In regards to the Labor Code claim, the court rejected Oracle's due process clause and commerce clause arguments; in regards to the California Business and Professions Code 17200 claim, the court held that the California court's holding was conclusive (that section 17200 did not apply to overtime work performed by plaintiffs); and in regards to the Fair Labor Standard Act (FLSA), 29 U.S.C. 213(a)(1), claim, the court held that the California court's holding was conclusive (section 17200 did not apply to overtime work performed outside California for a California-based employer by out-of-state plaintiffs based solely on the employer's failure to comply with the overtime provisions of the FLSA).