Justia Constitutional Law Opinion Summaries

Integrity and Buentello filed suit against the City, alleging that its refusal to include them on the non-consent tow list violated the Equal Protection Clause of the Fourteenth Amendment. On appeal, the City challenged the district court's order requiring it to include plaintiffs on the City's non-consent tow list and to develop neutral criteria for that list. The court has previously held that a class-of-one equal-protection claim is unavailable in a public employment context. The court concluded that this conclusion logically applies as well to a local government’s discretionary decision to include or not include a company on a non-consent tow list. In the alternative, the court concluded that Integrity and Buentello’s class-of-one equal-protection claim fails because they have not shown that the City had a discriminatory intent and because the City has a rational basis for excluding them. Accordingly, the court reversed and rendered a judgment of dismissal for the City. View "Integrity Collision Center v. City of Fulshear" on Justia Law

Plaintiff, an evangelical Christian, filed suit against the City, alleging that he was denied his First Amendment right to hand out religious literature at a public festival. The parties entered into a consent decree where the City agreed to pay plaintiff a dollar in nominal damages and where, among other provisions, the City was prohibited from interfering with plaintiff's free speech rights or other individuals at future public events in downtown Ft. Worth. At issue are the attorney's fees. Because a plaintiff is a prevailing party when nominal damages are awarded, and this case does not present the special circumstances in which a prevailing civil rights plaintiff may be denied fees altogether, the court vacated the order denying fees and remanded for an assessment of the reasonableness of the fee request. View "Grisham v. City of Fort Worth" on Justia Law

After the City terminated plaintiff, he filed suit alleging disability discrimination claims. The district court granted summary judgment to the City. The court concluded that the district court correctly held that plaintiff failed to raise an issue of material fact as to whether the City terminated him because of his disability where there is no evidence that the City’s reliance on his history of misconduct and poor performance was pretextual or blended with discriminatory motives. The court saw no basis for concluding that the City failed to engage in good faith by not finding him a new position after he had shown no desire to try and succeed in the first position. The court concluded that, given the undisputed evidence that plaintiff did not make an honest attempt to succeed in the new position, he cannot make out a claim placing blame for the breakdown in the accommodation process on the City. Accordingly, the court affirmed the judgment. View "Dillard v. City of Austin" on Justia Law

After Officers Zoss, Mayo, and Ballew forcibly removed William Sullivan from his pickup truck after he refused to comply with their lawful commands to exit the vehicle, Sullivan - who was heavily intoxicated, morbidly obese, and handicapped - suffered a serious injury rendering him a quadriplegic. Sullivan died a few months later. The district court denied the officers' motion for summary judgment based on qualified immunity. The court concluded that the district court erred because, even on plaintiffs’ version of the tragic facts, the officers did not violate Sullivan’s constitutional rights. In this case, the approximately two minutes that Zoss spent negotiating with Sullivan before deciding to resort to force was not objectively unreasonable, especially in light of, inter alia, Sullivan’s explicit and repeated refusal to comply with Zoss’s requests to exit the pickup and the possibility that Sullivan might have had access to a weapon or could have tried to drive his huge, elevated truck into the police car. Accordingly, the court reversed and remanded. View "Sullivan v. City of Round Rock" on Justia Law

In response to secretly recorded videos released by the Center for Medical Progress depicting conversations with Planned Parenthood employees elsewhere, LDHH terminated PPGC Louisiana Medicaid provider agreements. PPGC and the Individual Plaintiffs filed suit against LDHH under 42 U.S.C. 1983, alleging violations of 42 U.S.C. 1396a(a)(23) and the First and Fourteenth Amendments of the U.S. Constitution. The Individual Plaintiffs, three women who are Medicaid beneficiaries and who receive medical care from one of PPGC’s Louisiana facilities, seek to continue receiving care from PPGC’s facilities. The Individual Plaintiffs contend that LDHH’s termination action will deprive them of access to the qualified and willing provider of their choice, PPGC, in violation of Medicaid’s free-choice-of-provider provision. The district court entered a preliminary injunction against LDHH’s termination of PPGC’s Medicaid provider agreements. The court held that the Individual Plaintiffs met their burden to show their entitlement to a preliminary injunction; the district court did not abuse its discretion in preliminarily enjoining LDHH’s termination of PPGC’s provider agreements; and thus the court affirmed the district court's preliminary injunction, remanding for further proceedings. View "Planned Parenthood v. Gee" on Justia Law

After plaintiff spent 16 days in county jail for an assault he did not commit, he filed suit under 42 U.S.C. 1983 against Kelly Phillips, a sheriff’s office deputy. Plaintiff alleged that Phillips intentionally or recklessly misidentified him as the assailant in an offense report that he prepared, thereby leading to plaintiff’s arrest without probable cause in violation of the Fourth Amendment. The district court denied Phillips's motion for summary judgment based on qualified immunity. The court affirmed the district court’s ruling that, under these circumstances, Phillips may be liable for Fourth Amendment violations under Franks v. Delaware even though he neither signed nor drafted the affidavit in support of the warrant for plaintiff’s arrest; in reviewing an interlocutory appeal from the denial of a motion for summary judgment qualified immunity, the court lacked jurisdiction to review the district court’s finding of a genuine fact dispute as to Phillips’s recklessness; and, assuming plaintiff's factual assertions are true, the independent intermediary doctrine does not apply to shield Phillips from liability. Accordingly, the court dismissed Phillips’s appeal to the extent he challenges the district court’s finding of genuine disputes of fact, and affirmed in all other respects. View "Melton v. Phillips" on Justia Law

Plaintiff, a former prisoner, filed suit against four Dallas County Jail detention officers under 42 U.S.C. 1983 and state law. Plaintiff claims that the officers beat him without justification. The jury found Special Response Team Officer Erwin liable as to all claims, and awarded both compensatory and punitive damages. The court concluded that the district court did not abuse its discretion in concluding that plaintiff complied with the Prison Litigation Reform Act's (PLRA), 42 U.S.C. 1997(e)(a), exhaustion requirement; sufficient evidence supports the jury's verdict finding Erwin liable for excessive force; the court need not address Erwin’s challenges to the jury’s findings of section 1983 bystander liability or assault under state law, as Erwin’s liability for excessive force is alone sufficient to uphold the verdict; the court rejected Erwin's challenges to the jury's award of damages; and the result in this case does not reflect a miscarriage of justice and the district court acted within its discretion in denying Erwin’s new trial motion. Accordingly, the court affirmed the judgment. View "Cowart v. Erwin" on Justia Law

Five men convicted of murder and sentenced to die by lethal injection (Appellants) filed suit under 42 U.S.C. 1983, alleging constitutional violations in connection to the state's use of pentobarbital to induce death. Three of the five received stays from the Texas Court of Criminal Appeals on state habeas petitions presenting claims not at issue here. The remaining two argue that Texas is obliged by the Eighth Amendment’s prohibition on cruel and unusual punishment and the Fourteenth Amendment’s guarantee of equal protection under the law to re-test the execution drug to assure it does not present a high risk of unnecessary pain. The court concluded that appellants' claims are meritless and that they have failed to make the showing required for a stay pending appeal. Accordingly, the court denied their motion for a stay of execution. View "Wood v. Collier" on Justia Law

Members of the clergy, organizations, and other citizens of the State of Mississippi challenging HB 1523. HB 1523 declares that its aim is “to provide certain protections regarding a sincerely held religious belief or moral conviction for persons, religious organizations and private associations.” The Act enumerates the beliefs as follows: “(a) Marriage is or should be recognized as the union of one man and one woman; (b) Sexual relations are properly reserved to such a marriage; and (c) Male (man) or female (woman) refer to an individual’s immutable biological sex as objectively determined by anatomy and genetics at time of birth.” The district court determined that it should preliminarily enjoin the enactment and enforcement of HB 1523. The State moved for a stay pending appeal. The court denied the State's motion for stay pending appeal and its motion to expedite this appeal. The court granted the State’s motion to consolidate this case with 16-60478, Campaign for Southern Equality, et al v. Phil Bryant, et al. The court's decision maintains the status quo in Mississippi as it existed before the Legislature’s passage and attempted enactment of HB 1523. View "Barber v. Bryant" on Justia Law

Plaintiff, on behalf of himself and others similarly situated, filed suit against Coca-Cola, alleging claims under Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff alleged that Coca-Cola owns and operates glass-front vending machines in public spaces and that those machines are not accessible to him and others who are blind. The district court dismissed the complaint, holding that Coca-Cola’s vending machines are not themselves “places of public accommodation.” Based on the unambiguous language of 42 U.S.C. 12181(7)(E), the court concluded that Coca-Cola’s vending machines are not “sales establishments” under the plain meaning of that term and therefore are not “places of public accommodation” under Title III of the ADA. Therefore, the court need not consider whether the vending machines are “facilities” under 28 C.F.R. 36.104. The court noted that its conclusion comports with the statute’s legislative history and the DOJ’s guidance. The court acknowledged the limits of its holding and noted that vending machines may very well be subject to various requirements under the ADA by virtue of their being located in a hospital or a bus station, both of which are indisputably places of public accommodation. However, plaintiff only sued Coca-Cola in this case. Accordingly, the court affirmed the judgment. View "Magee v. Coca-Cola Refreshments USA Inc." on Justia Law