Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against three charitable organizations, alleging that they unlawfully refused to admit her to homeless shelters because of her alleged mental health disability. The district court dismissed the claims under 28 U.S.C. 1915(e)(2)(B)(ii) for failure to state a claim on which relief could be granted. The court concluded that plaintiff's 42 U.S.C. 1983 claim cannot proceed because none of the defendants are state actors; plaintiff's 42 U.S.C. 1985 claim of civil conspiracy between the Salvation Army and Church in the City must also be dismissed because there are no allegations to support the existence of any conspiracy; plaintiff lacks standing to bring a claim under the Americans with Disabilities Act, 42 U.S.C. 12101 et seq.; plaintiff's Fair Housing Act, 42 U.S.C. 3601 et seq., claim was properly dismissed because her complaint does not contain a plausible allegation of discrimination; and plaintiff's claim under the Rehabilitation Act, 29 U.S.C. 794, was also properly dismissed. Accordingly, the court affirmed the judgment of dismissal as modified to indicate that it be without prejudice. View "Thomas v. The Salvation Army" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against various Detention Facility officials, arguing that the imposition of disciplinary segregation without a hearing violated his procedural due process rights. The district court granted summary judgment to defendants, concluding that due process requirements were satisfied by plaintiff's opportunity to file a written appeal after he was placed in disciplinary segregation. The court concluded, however, that as a pretrial detainee, plaintiff was entitled to a hearing before he was punished. In this case, defendants concede that no such hearing was afforded and thus the court directed that judgment be entered for plaintiff on his due process claim. The court remanded for consideration of plaintiff's excessive force claim under the proper standard. View "Dilworth v. Adams" on Justia Law

Plaintiff, a former federal prisoner, filed suit alleging a number of violations under the Fourth, Fifth, Eighth, and Fourteenth Amendments, against several federal prison officials pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. On appeal, plaintiff challenged the district court's grant of defendants' motion for summary judgment. Plaintiff argues that, in dismissing three claims that defendants were deliberately indifferent to his medical needs, the district court made credibility determinations and weighed the parties’ evidence, thus violating the summary judgment standard. The court reversed the district court's disposition of the two Eighth Amendment claims against Dr. Phillip and Administrator McClintock. In this case, the court concluded that there is sufficient evidence that plaintiff’s Eighth Amendment right to adequate medical care and freedom from officials’ deliberate indifference to his medical needs was violated and that the right was clearly established. The court affirmed the district court's resolution of the claim against Warden Stansberry. View "Scinto, Sr. v. Warden Stansberry" on Justia Law

The district court determined that the Board's practice of opening its public meetings with an invocation delivered by a member of the Board violates the Establishment Clause of the First Amendment. In Town of Greece v. Galloway, the Supreme Court held that the legislative prayer in that case, although clearly sectarian, was constitutionally valid and did not transgress the Establishment Clause. Town of Greece guides the court's review of this case, which requires a case-specific evaluation of the facts and circumstances. The court concluded that the district court erred in determining that the fact that a legislator delivers a legislative prayer is a significant constitutional distinction; the Board’s legislative prayer practice amounts to nothing more than an individual commissioner leading a prayer of his or her own choosing; given the respectful tone of nearly all the invocations delivered here, which largely mirror those identified in Town of Greece, the Board’s practice crossed no constitutional line; a party challenging a legislative prayer practice cannot rely on the mere fact that the selecting authority has confined the invocation speakers to a narrow group; the prayers in this case, like those in Town of Greece, were largely generic petitions to bless the commissioners before turning to public business; and the district court erred in concluding the Board’s prayer practice was coercive. Because none of the constitutional contentions raised by plaintiffs have validity under the facts of this case, the court reversed and remanded with directions to dismiss the complaint. View "Lund v. Rowan County, NC" on Justia Law

These consolidated cases challenge provisions of a recently enacted North Carolina election law. Session Law 2013-381.2 imposed a number of voting restrictions. The law required in-person voters to show certain photo IDs, beginning in 2016, which African Americans disproportionately lacked, and eliminated or reduced registration and voting access tools that African Americans disproportionately used. Prior to the enactment of SL 2013-381, the legislature requested and received racial data as to usage of the practices changed by the proposed law. Upon receipt of the race data, the General Assembly enacted legislation that restricted voting and registration in five different ways, all of which disproportionately affected African Americans. The court concluded that the asserted justifications for the law cannot and do not conceal the State’s true motivation: taking away minority voters' opportunity because they were about to exercise it. Therefore, the court concluded that the General Assembly enacted the challenged provisions of the law with discriminatory intent. The court reversed and remanded with instructions to enjoin the challenged provisions of the law. View "N.C. State Conference v. McCrory" on Justia Law

After plaintiff was arrested for obstruction of justice and the charge was ultimately dismissed, plaintiff filed suit against the police officers responsible for her arrest, alleging that the officers violated her Fourth Amendment rights by arresting her without probable cause. The district court granted the officers' motion for qualified immunity. The court concluded that it would be clear to officers in defendants' position that they lacked probable cause to arrest defendant where the court could not find in the record any attempted action by the officers that could be said to have been "obstructed" by plaintiff, and the officers' brief and oral argument are likewise missing even a suggested action that was actually obstructed. Accordingly, the court reversed and remanded. View "Graham v. Gagnon" on Justia Law

After plaintiff was terminated from his position as a police officer, he filed suit under 42 U.S.C. 1983, alleging retaliatory discharge in violation of the First Amendment based on the comments he made as a candidate for town council that were critical of his employer. The district court denied Police Chief Rob Hall qualified immunity. The court concluded, however, that Hall is entitled to qualified immunity because it was debatable at the time of plaintiff's dismissal that his speech interests as a citizen outweighed Hall’s interests as a public employer. Accordingly, the court reversed and remanded. View "Brickey v. Hall" on Justia Law

After William Gault terminated plaintiff from her position as deputy clerk, plaintiff filed suit challenging her termination on First Amendment grounds. The district court granted defendant's motion for summary judgment, holding that plaintiff occupied a confidential or policymaking position and was subject to termination for campaigning against her boss. The court reversed the district court’s decision to grant summary judgment to Gault based on the Elrod-Branti exception, determining that it could not, as a matter of law, conclude that party affiliation is an appropriate requirement for the effective performance of plaintiff's former position as a deputy clerk; Gault has not established the defense of qualified immunity; the court found unpersuasive Gault's contention that the Eleventh Amendment immunizes him from suit for monetary damages in his official capacity; and the history of this case does not present the court with an adequate Pickering record to review. The court vacated and remanded for further proceedings. View "Lawson v. Union County Clerk of Court" on Justia Law

After plaintiff was severely beaten by a fellow inmate, plaintiff filed suit against correctional officers, alleging that they were deliberately indifferent to a substantial risk to his safety in violation of 42 U.S.C. 1983. The district court denied summary judgment to the correctional officers based on qualified immunity. In light of the facts as the court may view them, and drawing reasonable inferences in plaintiff’s favor, the court found that the district court correctly held that material issues of fact precluded summary judgment for the correctional officers on the Eighth Amendment deliberate indifference claim. The court also concluded that an objectively reasonable correctional officer would have known that these actions were unreasonable, ran afoul of clearly established law, and violated plaintiff's rights. Accordingly, the correctional officers are not entitled to qualified immunity and the court affirmed the judgment. View "Cox v. Quinn" on Justia Law

Plaintiff, an Arab-American Muslim woman from Morocco, filed suit against Fairview, alleging claims, pursuant to 42 U.S.C. 1981, for race discrimination (Count I), hostile work environment (Count II), and retaliation (Count III); and pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000(e) et seq., claims for discrimination based on religion, national origin, and pregnancy (Count IV), hostile work environment (Count V), and retaliation (Count VI). The district court granted summary judgment for Fairview on all six counts. In regard to the discrimination and retaliation counts, the court concluded that the evidence was sufficient to meet plaintiff's burden to show pretext. In this case, the evidence supports plaintiff's argument that when she complained to her supervisor, who was also her alleged harasser, the supervisor decided to terminate her and immediately got the decision approved. Furthermore, the absence of any evidence to support Fairview’s lack-of-work explanation is also important. Although Fairview claims that there were discussions of eliminating plaintiff's position in the past, there is no record evidence to support that claim. Accordingly, the court reversed and vacated as to Counts III and VI. Likewise, the court reversed as to the remaining counts. By failing to address numerous comments that were open to a racially motivated interpretation, and by circumscribing its analysis to just one comment without reviewing the totality of the circumstances, the district court committed reversible error in its grant of summary judgment for Fairview. View "Guessous v. Fairview Property Investments" on Justia Law