Justia Constitutional Law Opinion Summaries

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

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

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

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

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

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

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

Two former sheriff's deputies were terminated for violating the Sheriff's Code of Conduct because they moved in with each other's wife and family before getting divorced from their current wives. The district court held that the Code policies invoked against the deputies were supported by the rational grounds of preserving a cohesive police force and upholding the public trust and reputation of the Sheriff's Department, and that the Code was not unconstitutionally vague as written or enforced. The Fifth Circuit affirmed the district court's judgment in favor of defendants, holding that the district court made no reversible error of fact or law. The court explained that Obergefell v. Hodges does not alter applicable law, and did not create "rights" based on relationships that mock marriage. View "Coker, v. Whittington" on Justia Law

Pursuant to the Prison Litigation Reform Act (PLRA), 28 U.S.C .1915(g), a third strike bars a prisoner from proceeding in forma pauperis unless the prisoner is under imminent danger of serious physical injury. A strike issues when a prisoner's action is dismissed as frivolous, malicious, or for failure to state a claim. However, a strike does not issue when only some claims are dismissed on section 1915(g) grounds. In this case, plaintiff's claims were dismissed for failure to state a claim while others were adequately pleaded but failed at summary judgment. The Fifth Circuit affirmed the dismissal of plaintiff's claim that defendants were deliberately indifferent to his serious medical needs, but vacated the strike because the strike did not issue when only some of plaintiff's claims were dismissed on section 1915(g) grounds. View "Brown v. Megg" on Justia Law

Petitioner challenged the district court's transfer of his habeas petition to the Fifth Circuit based on the ground that the petition was second or successive. The Fifth Circuit affirmed the transfer order, holding that there was no intervening judgment here because the 2014 Texas Court of Criminal Appeal decision was not the one authorizing petitioner's confinement. In the alternative, the Fifth Circuit found that petitioner had made a requisite prima facie showing to file a successive habeas petition and the court granted his motion for authorization to file a successive petition. In this case, petitioner's Atkins claim relied on a previously unavailable new rule of constitutional law and his Atkins claim had merit. View "In Re: Eric Cathey" on Justia Law