Justia Constitutional Law Opinion Summaries

After plaintiff, who was twenty-seven years old at the time, was excluded from the presidential primary ballot under California law, she filed suit under the First Amendment, the Equal Protection Clause of the Fourteenth Amendment, and the Twentieth Amendment. The district court dismissed the case with prejudice. The court concluded that the case was not moot because it was "capable of repetition, yet evading review." The court concluded that age requirements, like residency requirements and term limits, are neutral candidacy qualifications which the State had the right to impose; any burden on plaintiff's speech and association rights were minimal; and the burden was justified by California's asserted interest in protecting the integrity of the election process and avoiding voter confusion. The court rejected plaintiff's Equal Protection claim; because including ineligible candidates on the ballot could easily cause voter confusion, treating ineligible candidates differently from eligible ones was rationally related to the state's interest in maintaining the integrity of the election process; and the Secretary did not violate the Equal Protection Clause by excluding from the ballot candidates who are indisputably ineligible to serve, while listing those with a colorable claim of eligibility. Even if the Twentieth Amendment gave rise to a private right of action, nothing in the Twentieth Amendment states or implies that Congress has the exclusive authority to exclude a candidate with a known ineligibility from the presidential ballot. Accordingly, the court affirmed the judgment of the district court. View "Lindsay v. Bowen" on Justia Law

Plaintiff, currently incarcerated at SRCI, filed suit pro se under 42 U.S.C. 1983, alleging that prison officials violated his due process rights by housing him in the Intensive Management Unit (IMU) for twenty-seven months without periodic, meaningful review of his status. The court concluded that plaintiff's conditions of confinement in the IMU implicated a protected liberty interest under any plausible baseline. Nonetheless, the court concluded that plaintiff's claims against the Oregon Department of Corrections and his damages claims against the individual defendants in their official capacities were barred by the Eleventh Amendment. Plaintiff's remaining damages claims were barred by qualified immunity. The court affirmed the district court's grant of summary judgment on plaintiff's claim for declaratory relief because the record showed that plaintiff had been released from the IMU and there was no evidence that he was likely to again be subject to the challenged conditions. View "Brown v. Oregon Dept. of Corr." on Justia Law

Plaintiff filed suit against defendants in the Superior Court of Guam, asserting claims arising from alleged breach of fiduciary duty in the course of the parties' several business ventures. Defendants removed to the District Court of Guam based on diversity jurisdiction. Plaintiff is an alien admitted to the United States for permanent residence, living in Guam. Defendant Lai, a British Overseas Citizen, and Defendant Sekiguchi, a Japanese citizen, both live in Japan. The district court granted summary judgment on the merits in favor of defendants and plaintiff appealed, contesting subject matter jurisdiction for the first time. Whether or not Congress intended to confer jurisdiction in cases like this one by supplying constitutionally required minimal diversity through deemed citizenship, the deeming clause purported to do so. The court concluded, however, that the Organic Act of Guam, 48 U.S.C. 1421-1421k-1, precluded it from deciding the merits of the dispute between aliens because it conferred diversity jurisdiction upon the District Court of Guam reaching only as far as the diversity jurisdiction afforded to Article III courts. Because the Constitution does not supply diversity jurisdiction to Article III courts in suits between aliens, the jurisdiction afforded the federal court in Guam must also be so limited. Accordingly, the court vacated and remanded, concluding that both the court and the District Court of Guam lacked jurisdiction to decide this dispute exclusively between aliens. View "Yokeno v. Sekiguchi" on Justia Law

Plaintiff was convicted at his first trial of first degree murder in which the prosecutor relied on evidence obtained in violation of his Miranda rights, and after the conviction was reversed he was again convicted, this time without the use of the illegally obtained evidence. Plaintiff filed suit under 42 U.S.C. 1983 for damages as result of his conviction for first degree murder in violation of his Fifth Amendment rights. The court held that plaintiff's section 1983 claim against Sheriff Barnes for the Fifth Amendment violation was not barred by Heck v. Humphrey. Under Heck and Trimble v. City of Santa Rosa, plaintiff's Fifth Amendment claim was not time-barred, and plaintiff may be able to show that he is entitled to damages, especially nominal damages, for the Miranda violation. Therefore, the court reversed the district court's dismissal of that claim. The court held that plaintiff properly pleaded a claim of Monell liability against the Sheriff's Department, and that the Sheriff's Department was subject to suit under section 1983 for its investigative activities. Therefore, the court reversed the district court's dismissal of this claim. Finally, the court affirmed the district court's dismissal of plaintiff's claim against the District Attorney's Office, but instructed it to grant plaintiff leave to amend his complaint to state a claim against District Attorney Murphy. View "Jackson v. Barnes, et al." on Justia Law

CNS filed suit against defendant, the Executive Officer/Clerk of the Ventura County Superior Court, alleging that the Ventura County Superior Court's failure to provide same-day access to newly filed unlimited civil complaints violated its right of access to public judicial proceedings under the First Amendment. On appeal, CNS challenged the district court's order dismissing his complaint for declaratory and injunctive relief. The district court granted defendant's motion to abstain from hearing the case under Railroad Commission of Texas v. Pullman Co., and O'Shea v. Littleton, which permitted the federal district courts to decline to decide matters over which they have jurisdiction but which implicated sensitive state interests. The court concluded that CNS's First Amendment right of access claim fell within the general rule against abstaining under Pullman in First Amendment cases. Though the government may sometimes withhold information without violating the expressive rights protected by the First Amendment, the First Amendment right of access to public proceedings was inextricably intertwined with the First Amendment right of free speech. It was well-established that the right of access to public records and proceedings was necessary to the enjoyment of the right to free speech. CNS's right of access claim implicated the same fundamental First Amendment interests as a free expression claim, and it equally commanded the respect and attention of the federal courts. Under either de novo review or the de novo component of the modified abuse of discretion standard applicable in most abstention cases, the court concluded that O'Shea abstention was also improper. An injunction requiring the Ventura County Superior Court to provide same-day access to filed unlimited civil complaints posed little risk of an ongoing federal audit or a major continuing intrusion of the equitable power of the federal courts into the daily conduct of state proceedings. Accordingly, the court reversed and remanded. View "Courthouse News Service v. Planet" on Justia Law

In enacting comprehensive welfare reform in 1996, Congress rendered various groups of aliens ineligible for federal benefits and also restricted states' ability to use their own funds to provide benefits to certain aliens. As a condition of receiving federal funds, Congress required states to limit eligibility for federal benefits, such as Medicaid, to citizens and certain aliens. Plaintiffs filed suit claiming that Basic Health Hawai'i violated the Equal Protection Clause of the Fourteenth Amendment because it provided less health coverage to nonimmigrant aliens residing in Hawai'i (COFA Residents) than the health coverage that Hawai'i provided to citizens and qualified aliens who are eligible for federal reimbursements through Medicaid. The court concluded that Congress has plenary power to regulate immigration and the conditions on which aliens remain in the United States, and Congress has authorized states to do exactly what Hawai'i had done here - determine the eligibility for, and terms of, state benefits for aliens in a narrow third category, with regard to whom Congress expressly gave states limited discretion. Hawai'i has no constitutional obligation to fill the gap left by Congress's withdrawal of federal funding for COFA Residents. Accordingly, the court vacated the district court's grant of a preliminary injunction preventing Hawai'i from reducing state-paid health benefits for COFA Residents because Hawai'i is not obligated to backfill the loss of federal funds with state funds and its decision not to do so was subject to rational-basis review. View "Korab v. Fink" on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983 and California law after police officers shot and killed Kamal Lal. The district court granted summary judgment for defendants, finding that the officers were entitled to qualified immunity. Lal lead police on a high speed chase for 45 minutes before the officers were able to disable his vehicle. In the four minutes that elapsed after Lal exited the truck, he first tried to seriously injure himself, tried to provoke the officers into shooting him, threw rocks at the officers, and then, ignoring instructions to stop, advanced upon the officers threatening them with a football-sized rock he held over his head. Under the totality of the circumstances, the district court's determinations that the officers objectively feared immediate serious physical harm and that a reasonable officer could have believed that Lal threatened him with immediate serious danger were sound. That Lal may have been intent on committing "suicide by cop" did not negate the fact that he threatened the officers with such immediate serious harm that shooting him was a reasonable response. According, the court affirmed the judgment of the district court. View "Lal v. California" on Justia Law

Plaintiff filed suit against JAL, alleging that JAL retaliated against him for reporting safety concerns and constructively terminated him for reasons related to his medical and mental fitness. At issue on appeal was whether the Federal Aviation Act of 1958 (FAA), 49 U.S.C. 40103 et seq., preempted plaintiff's state law claims. The court concluded that the FAA and accompanying regulations preempted plaintiff's retaliation and constructive termination claims. The court held that federal law preempted state law claims that encroached upon, supplemented, or altered the federally occupied field of aviation safety and presented an obstacle to the accomplishment of Congress's legislative goal to create a single, uniform, system of regulating that field. Further, the district court did not abuse its discretion in denying plaintiff's motion for reconsideration where he conceded that the conduct giving rise to his claims occurred in U.S. airspace. Accordingly, the court affirmed the district court's judgment in favor of JAL. View "Ventress v. Japan Airlines" on Justia Law

Plaintiff appealed the district court's order denying her motion for preliminary injunction of San Francisco Police Code sections 4512 and 613.10(g) on the ground that both infringed upon her Second Amendment rights. The court concluded that section 4512, which requires handguns to be stored in a locked container when not carried on the person, burdens the rights protected by the Second Amendment because storage regulations such as section 4512 are not part of a long historical "tradition of proscription;" section 4512 is not a substantial burden on the Second Amendment; and, applying intermediate scrutiny, the court concluded that section 4512 is substantially related to the important government interest of reducing firearm-related deaths and injuries. The court also concluded that section 613.10(g), which prohibits the sale of hollow-point ammunition within San Francisco, regulates conduct within the scope of the Second Amendment because restrictions on ammunition may burden the core Second Amendment right to self-defense and the record contained no persuasive historical evidence suggesting otherwise. Determining that plaintiff had standing to challenge section 613.10(g), the court concluded that section 613.10(g) is a reasonable fit to achieve its goal of reducing the legality of ammunition, and section 613.10(g) thus satisfies intermediate scrutiny. Accordingly, the court concluded that plaintiff would not succeed on the merits of her claims and affirmed the district court's denial of plaintiff's motion for preliminary injunction. View "Jackson v. City & Ctny. of San Francisco" on Justia Law

Plaintiff, a prisoner suffering from schizoaffective disorder and who is proceeding pro se, sought damages from California prison officials under 42 U.S.C. 1983. Plaintiff challenged the district court's denial of his request for a guardian ad litem because the Pro Bono Coordinator advised the court that no one was available to undertake the representation. In these consolidated appeals, at issue was whether the district court erred, under Rule 17(c)(2), by declining to appoint a guardian ad litem and instead staying plaintiff's cases indefinitely until he is found to be restored to competency. Determining that the court had jurisdiction over the appeal as a final decision under 28 U.S.C. 1291, or in the alternative, as a collateral order pursuant to Cohen v. Beneficial Industrial Loan Corp., the court concluded that the district court abused its discretion by staying plaintiff's cases until he was found competent (if ever). Such a stay order failed to adequately protect plaintiff's interest and thus did not constitute "another appropriate order" under Rule 17(c). Instead, it amounted to a dismissal with prejudice. Therefore, the court vacated and remanded with instructions. View "Davis v. Walker" on Justia Law