Justia Constitutional Law Opinion Summaries
Articles Posted in U.S. Court of Appeals for the Fifth Circuit
United States v. Cisneros
In January 2023, law enforcement executed a search warrant at Juan David Cisneros's residence, resulting from a narcotics investigation. They found ammunition in his bedroom but no drugs or firearms attributable to him. Cisneros admitted to using the ammunition previously but claimed his mother-in-law purchased it. He was charged with possessing ammunition as a convicted felon under 18 U.S.C. § 922(g)(1).The United States District Court for the Southern District of Texas denied Cisneros's motion to dismiss the indictment, which argued that § 922(g)(1) was unconstitutional under the Second Amendment and exceeded Congress's power under the Commerce Clause. Cisneros pleaded guilty but reserved the right to appeal on Second Amendment grounds. The court adopted the Presentence Investigation Report, which included a four-level enhancement for possessing ammunition in connection with drug trafficking, and sentenced him to ninety-six months in prison.The United States Court of Appeals for the Fifth Circuit reviewed the case. Cisneros's facial challenge to § 922(g)(1) was foreclosed by precedent, and his as-applied challenge failed under plain error review. The court affirmed his conviction, finding no clear or obvious error in the application of § 922(g)(1) under the Second Amendment.However, the court found that the district court plainly erred in applying the sentencing enhancement under U.S.S.G. § 2K2.1(b)(6)(B) for possessing ammunition in connection with another felony offense. The court noted that there was no evidence the ammunition facilitated drug trafficking, as required by precedent. This error affected Cisneros's substantial rights, as it likely resulted in a longer sentence. Consequently, the Fifth Circuit vacated Cisneros's sentence and remanded for resentencing. View "United States v. Cisneros" on Justia Law
Space Exploration Technologies Corp. v. National Labor Relations Board
Space Exploration Technologies Corp. (SpaceX) operates a space launch business and a global satellite-based internet service called Starlink. In June 2022, a group of SpaceX employees sent an open letter demanding certain actions from the company and solicited support through a survey. SpaceX discharged four employees involved in the letter's distribution for violating company policies. Additional employees were later discharged for lying during a leak investigation and for unrelated performance issues. These employees filed charges with the National Labor Relations Board (NLRB) in November 2022, alleging violations of the National Labor Relations Act.The NLRB Regional Director found merit in the claims and issued an order consolidating the employees' cases with a hearing set for March 2024. SpaceX sued the NLRB in the Southern District of Texas (SDTX) in January 2024, challenging the NLRB's structure as unconstitutional and seeking declaratory and injunctive relief. The NLRB moved to transfer the case to the Central District of California (CDCA), arguing improper venue. The SDTX granted the transfer motion in February 2024. SpaceX petitioned for an emergency writ of mandamus to vacate the transfer order, which was initially stayed but later denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. SpaceX argued that the district court effectively denied its motion for a preliminary injunction by failing to rule on it by May 2, 2024. The Fifth Circuit found that SpaceX did not demonstrate the "serious, perhaps irreparable, consequence" required for an immediate appeal. The court noted that participating in the administrative proceeding did not constitute irreparable harm and that the district court did not act unreasonably in waiting to resolve procedural challenges. Consequently, the Fifth Circuit dismissed SpaceX's appeal for lack of subject-matter jurisdiction. View "Space Exploration Technologies Corp. v. National Labor Relations Board" on Justia Law
Simpson v. Cisneros
Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law
Parker v. Hooper
In this case, inmates at the Louisiana State Penitentiary (LSP) filed a class action lawsuit in 2015 against the warden, the Louisiana Department of Public Safety and Corrections, and other officials. The plaintiffs alleged that the defendants were deliberately indifferent to their serious medical needs, violating the Eighth Amendment, the Rehabilitation Act of 1973, and the Americans with Disabilities Act (ADA). The district court bifurcated the case into liability and remedy phases. After an eleven-day bench trial, the court found in favor of the plaintiffs on all claims. Subsequently, a ten-day trial on remedies concluded that the plaintiffs were entitled to permanent injunctive relief, but the court did not specify the relief in its judgment.The United States District Court for the Middle District of Louisiana entered a "Judgment" in favor of the plaintiffs and a "Remedial Order" outlining the appointment of special masters to develop remedial plans. The defendants appealed, arguing that the district court's judgment and remedial order were final and appealable under 28 U.S.C. § 1291 or, alternatively, under 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the district court had not entered a final decision appealable under 28 U.S.C. § 1291, nor had it entered an injunction appealable under 28 U.S.C. § 1292(a)(1). The appellate court determined that the district court's actions were not final because they contemplated further proceedings, including the appointment of special masters and the development of remedial plans. Consequently, the Fifth Circuit dismissed the appeal for lack of jurisdiction and vacated the stay of the remedial order. View "Parker v. Hooper" on Justia Law
Virden v. City of Austin
Jennifer Virden, a small business owner in Austin, Texas, ran for city council in 2020 and for mayor in 2022. The City of Austin has a regulation that prohibits candidates from fundraising outside a one-year period before the general election. Virden announced her candidacy for the 2022 election in March 2021, which was seven months before she could start fundraising under the ordinance. She filed a lawsuit challenging the one-year fundraising window as unconstitutional under the First Amendment.The United States District Court for the Western District of Texas initially denied Virden's request for a preliminary injunction, finding no irreparable harm. Virden's interlocutory appeal was dismissed as moot after the fundraising window opened. The district court later granted summary judgment in part, ruling that the one-year fundraising window was unconstitutional and awarding nominal damages to Virden and her donor, William Clark. The court found that the claims for declaratory and injunctive relief were moot since the 2022 election had ended and there were no concrete plans for future campaigns. The court also refused to consider evidence regarding Virden's desire to contribute to another candidate in the 2024 election, deeming the submission untimely.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that the one-year fundraising window was unconstitutional, agreeing that it violated the First Amendment. The court also upheld the award of nominal damages to Virden and Clark. Additionally, the court found that the district court did not abuse its discretion in refusing to consider the late evidence regarding the 2024 election. The Fifth Circuit concluded that the suit was timely, Virden had standing, and the city's arguments were without merit. The court affirmed the district court's decision in its entirety. View "Virden v. City of Austin" on Justia Law
USA v. Peterson
George Peterson was investigated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) for illegal firearm transactions at his business, PDW Solutions, LLC, which he operated from his home. The ATF conducted undercover operations where Peterson sold firearms without reporting the transactions as required. Based on this, a magistrate judge issued a warrant to search Peterson's home and business. During the search, agents found an unregistered firearm suppressor in Peterson's bedroom-closet safe. Peterson was indicted for possession of an unregistered suppressor.The United States District Court for the Eastern District of Louisiana denied Peterson's pretrial motions to dismiss the indictment on Second Amendment grounds and to suppress the evidence on Fourth Amendment grounds. Peterson argued that the National Firearms Act's (NFA) registration requirement for suppressors violated his Second Amendment rights and that the search warrant lacked probable cause. The district court rejected these arguments, and Peterson entered a conditional guilty plea, reserving the right to appeal the denial of his motions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that suppressors are not "Arms" protected by the Second Amendment, as they are accessories and not weapons themselves. Therefore, the NFA's registration requirement does not violate the Second Amendment. Additionally, the court found that the good-faith exception to the exclusionary rule applied, as the officers reasonably relied on the warrant issued by the magistrate judge. The court affirmed the district court's denial of Peterson's motions to dismiss and suppress. View "USA v. Peterson" on Justia Law
Reese v. Bureau of Alcohol, Tobacco, Firearms, and Explosives
The case involves a challenge to the constitutionality of 18 U.S.C. §§ 922(b)(1) and (c)(1), which prohibit Federal Firearms Licensees (FFLs) from selling handguns to individuals aged eighteen to twenty. The plaintiffs, including individuals in this age group and several nonprofit organizations, argue that these provisions infringe on their Second Amendment rights and deny them equal protection under the Fifth Amendment.The United States District Court for the Western District of Louisiana found that the plaintiffs had standing but dismissed the case under Rule 12(b)(6). The district court assumed that the Second Amendment's plain text covered the purchase of firearms by eighteen-to-twenty-year-olds but concluded that the prohibition was consistent with the nation's historical tradition of firearm regulation, relying on the framework established by the Supreme Court in New York Rifle & Pistol Ass’n, Inc. v. Bruen.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the Second Amendment does cover the right of eighteen-to-twenty-year-olds to purchase firearms. The court found that the historical evidence presented by the government, including 19th-century laws, was insufficient to establish a tradition of restricting firearm rights for this age group in a manner similar to the contemporary federal handgun purchase ban. The court emphasized that the Second Amendment's protections extend to all law-abiding, adult citizens, including those aged eighteen to twenty.The Fifth Circuit held that 18 U.S.C. §§ 922(b)(1) and (c)(1) and their attendant regulations are unconstitutional as they are inconsistent with the nation's historical tradition of firearm regulation. The court reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Reese v. Bureau of Alcohol, Tobacco, Firearms, and Explosives" on Justia Law
United States v. Giglio
Damion Giglio, while on supervised release for a previous felony, was arrested and convicted for violating 18 U.S.C. § 922(g)(1), the felon-in-possession statute. He appealed, arguing that the statute is unconstitutional as applied to him and that the district court erred in calculating his sentencing guideline range, entitling him to a less severe sentence.The United States District Court for the Southern District of Mississippi denied Giglio's motion to dismiss the indictment, rejecting his constitutional challenge. Giglio pleaded guilty, and the court sentenced him to 27 months' imprisonment, noting that it would have imposed the same sentence regardless of any potential guideline calculation errors.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the government could regulate Giglio’s firearm possession without violating the Second Amendment, as historical practices support disarming individuals serving criminal sentences. The court also found that any error in the sentencing guideline calculation was harmless because the district court explicitly stated it would have imposed the same sentence regardless of the guideline range.The Fifth Circuit affirmed the district court's decision on both grounds, upholding Giglio's conviction and sentence. View "United States v. Giglio" on Justia Law
Duarte v. City of Lewisville, Texas
Plaintiff and his family challenged the City's ordinance restricting where certain individuals convicted of sex offenses may live within the city. The Fifth Circuit affirmed the district court's grant of summary judgment for the city, holding that even assuming the ordinance deprived plaintiff of a liberty interest, due process does not entitle him to a hearing to establish a fact that is not material under the statute. In this case, the fact that defendant seeks to prove his current dangerousness is of no consequence under the ordinance. The court also held that the ordinance did not violate the Equal Protection Clause because its challenged classification rationally furthers a legitimate state interest. View "Duarte v. City of Lewisville, Texas" on Justia Law
Coleman v. Lincoln Parish Detention Center
Plaintiff appealed the dismissal of his 42 U.S.C. 1983 pro se complaint as frivolous and for failure to state a claim. The Fifth Circuit affirmed, holding that plaintiff's claims for declaratory and injunctive relief under the Religious Land Use and Institutionalized Persons Act (RLUIPA), was moot after his transfer to a different detention center; plaintiff's First Amendment claim failed because, other than not being allowed to attend Jumu'ah prayer services, he has not identified any other restrictions on his ability to express or exercise his faith; plaintiff's claims regarding the denial of medical care, negligent or deliberately indifferent infliction of injury, interference with his mail/denial of access to the courts, denial of equal protection, and retaliation were either not briefed at all or not adequately briefed; and plaintiff filed a formal motion requesting leave to file his proposed third amended complaint, and his "proposed order" accompanying that complaint did not qualify as such a motion. The court denied plaintiff's motion for a proposed settlement, and noted that the dismissal of this complaint counts as a strike under 28 U.S.C. 1915(g). Because plaintiff has at least three other strikes, he is barred from proceeding in forma pauperis. View "Coleman v. Lincoln Parish Detention Center" on Justia Law