Justia Constitutional Law Opinion Summaries

Petitioner was convicted in California state court of first degree murder and subsequently appealed the district court's denial of his federal habeas petition. Petitioner challenged the admission at trial of the non-testifying autopsy pathologist's opinion, claiming violations of his Sixth Amendment right to confront witnesses against him. Because the chain of causation began as tenuous, continued to be disputed and was described inconsistently by the experts, the erroneous admission of the autopsy pathologist's non-cumulative opinion testimony likely had a substantial and injurious effect on the jury's verdict. Furthermore, it was impossible to say beyond a reasonable doubt of the autopsy pathologist's opinion did not contribute to petitioner's conviction. Accordingly, because the California Court of Appeal unreasonably applied clearly established Supreme Court Confrontation Clause jurisdiction to the facts and the error was prejudicial, the judgment of the district court was reversed and the case remanded with direction to vacate the murder conviction and issue the writ.

Plaintiffs appealed the adverse summary judgment grant in their 42 U.S.C. 1983 action arising out of the nighttime SWAT team search of their home for weapons suspected of being used in a drive-by shooting and stored in their home by their son. Plaintiffs alleged that their Fourth Amendments rights were violated by the issuance and execution of a search warrant whose application failed to disclose that their son was at that time, and for over six months had been, incarcerated and was therefore not present in plaintiffs' home, but moreover could not have been involved in the shooting or the storage of weapons used in it. Because plaintiffs presented sufficient evidence establishing a genuine issue as to whether Santa Maria Police Department Detective Louis Tanore's omission of this material fact was intentional or reckless, as opposed to merely negligent, the court reversed the summary judgment grant in his favor and remanded.

Petitioners challenged the prosecution's use of peremptory strikes to exclude black jurors in their trial. A magistrate judge, after holding an evidentiary hearing at which the prosecutor testified, found that he had purposefully discriminated on the basis of race in exercising a peremptory strike against one of the black jurors. The district judge, without holding a new evidentiary hearing, rejected the magistrate judge's finding as to the prosecutor's lack of credibility in asserting race-neutral reasons for having stricken the juror. In doing so, the district judge denied petitioners the process that they were constitutionally due. The court held that the rule of United States v. Ridgeway extended to determinations by a magistrate judge as to the credibility of a prosecutor's testimony at the second and third steps of the inquiry required by Batson v. Kentucky. Therefore, the district court erred in declining the opportunity to observe the trial prosecutor's demeanor before rejecting the magistrate judge's adverse credibility finding. The court vacated the district court's denial of the writ of habeas corpus and remanded for the district judge either to accept the magistrate judge's credibility finding or to conduct a new evidentiary hearing.

Plaintiff, who had a history of depression and bipolar disorder, filed a complaint against the Board when she was terminated from her position when she failed to complete at least six semester hours of professional development training to renew her certificate. At issue was whether a disabled teacher was a "qualified individual with a disability" under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court held that because plaintiff did not allege that the Board's legal authorization requirement was itself discriminatory, her failure to satisfy such requirement rendered her unqualified and the Board was not required to accommodate her disability. Accordingly, the judgment was affirmed.

In sentencing defendant following her conviction on immigration and bail-jumping charges, the district court made a number of comments suggesting that the length of the sentence imposed was determined at least in part by a desire to ensure that defendant received drug treatment while in prison. The court affirmed defendant's sentence but the Supreme Court reversed, remanding to the court to determine whether defendant was entitled to relief despite her failure to object to her sentence when it was imposed. The court held that the district court's consideration of defendant's rehabilitative needs in determining her sentence constituted plain error. Therefore, the court vacated the sentence and remanded for resentencing.

Petitioner was convicted in a California state court of first degree murder, with a finding of the special circumstance of killing a law enforcement officer engaged in the lawful pursuit of his duties, and was sentenced to death. Petitioner appealed from the district court's denial of his petition for habeas corpus. Petitioner's appeal required the court to consider and apply the United States Supreme Court decision in Cullen v. Pinholster. Under the circumstances, the court concluded that Pinholster was applicable and prevented the court from considering the new evidence in reviewing petitioner's Brady claim under 28 U.S.C. 2254(d). In light of Pinholster's emphasis on the primary responsibility of the state court, the court concluded that the new evidence needed to be presented to the state court before it could be considered by the court on habeas review of the state court's decision. The court concluded that petitioner had a colorable or potentially meritorious Brady claim such that a reasonable state court could find a Brady violation. The court affirmed all of the district court's rulings on all of the non-Brady claims.

Petitioner, a lawful permanent resident of the United States, was ordered removed on the ground that he had been convicted of an aggravated felony. Petitioner contended that the evidence was insufficient to establish that the crime of which he was convicted was an aggravated felony. The court concluded that petitioner's conviction of first-degree burglary was a conviction of an aggravated felony, and was sufficiently established by the state court's abstract of judgment. The court also rejected petitioner's ineffective assistance of counsel claim and accordingly denied the petition for review.

Defendant was convicted of fraud on two banks and was sentenced to one day of prison on each count and five years of supervised release, as well as restitution. Defendant subsequently violated his terms of supervised release on multiple occasions and was eventually sentenced to 24 months in prison to be followed by another 24 months of supervised release. The judge had given defendant more time in prison in order to facilitate his rehabilitation. At issue on appeal was whether rehabilitation could be considered for purposes of imposing imprisonment upon revocation of supervised release. The court overruled United States v. Duran and held that Tapia v. United States was the controlling statutory construction where rehabilitative benefits could not be the reason for imposing a prison sentence. Accordingly, defendant's sentence was vacated and the case remanded.

In a petition for writ of mandamus, petitioners challenged the district court's order denying their motion to intervene and be heard at defendant-real party in interest's sentencing hearing as purported crime victims under the Crime Victims Rights Act (CVRA), 18 U.S.C. 3771. The district court held that the rights provided by the CVRA did not apply to petitioners, and also declined to exercise discretion to hear and consider petitioners' proffered evidence. The court reviewed the record and concluded that petitioners have not met their burden and the trial judge did not clearly err as a matter of law, nor did he abuse his discretion. Accordingly, the court denied the petition for writ of mandamus under either the CVRA or the court's traditional mandamus authority.

Plaintiffs challenged the constitutionality of the ban on compensation for human organs in the National Organ Transplant Act, 42 U.S.C. 274e, as applied to bone marrow transplants. Plaintiffs sought declaratory and injunctive relief to allow harvesting of hematopoietic stem cells which would be extracted by peripheral blood stem cell apheresis (the same technique sometimes used to collect plasma or platelets). The court concluded that Congress made a distinction between body material that was compensable and body material that was not. The distinction had a rational basis, so the prohibition on compensation for bone marrow donations by the aspiration method did not violate the Equal Protection Clause. The court also concluded that when the peripheral blood stem cell apheresis method of bone marrow transplantation was used, it was not a transfer of a "human organ" or a "subpart thereof" as defined by the statue and regulation, so the statue did not criminalize compensating the donor. Therefore, the court need not decide whether prohibiting compensation for such donations would be unconstitutional.