Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against Defendant Terry and others after he was pulled over, tased three times, and arrested. Plaintiff was charged with an excessive noise violation, no license in possession, and disorderly conduct, all of which were nol prossed. The parties filed a stipulation of dismissal as to all claims except for the 42 U.S.C. 1983 claim for excessive force against Terry in his individual capacity. The district court denied Terry summary judgment based on qualified immunity. The court's analysis of the Graham v. Connor factors when measured against the level of force used by Terry against plaintiff leads the court to conclude that such force was not objectively reasonable in light of the totality of the circumstances in this case. Therefore, plaintiff has established that Terry's use of his taser constituted excessive force in violation of plaintiff's Fourth Amendment rights. Further, no reasonable officer would have believed that Terry’s use of the taser was justifiable at all and certainly not on three occasions. Accordingly, the court affirmed the district court’s denial of Terry’s motion for summary judgment based on qualified immunity. View "Yates v. Terry" on Justia Law

Plaintiff, an inmate at a Virginia correctional facility, filed suit under 42 U.S.C. 1983, alleging that defendant's deliberate indifference to plaintiff's safety, and the resulting injuries, constituted cruel and unusual punishment in violation of the Eighth Amendment. Plaintiff was attacked by his cellmate after requesting a transfer from defendant, the Prison Housing Manager. The court concluded that genuine disputes of material fact underlie plaintiff's claim where plaintiff alleged specific facts describing the injuries he sustained as a result of the attack, and alleged two independent grounds for establishing defendant's subjective knowledge of the risk of assault. Therefore, the district court erred in granting summary judgment to defendant. The court vacated and remanded. View "Raynor v. Pugh" on Justia Law

Plaintiff filed suit after her termination against her former employers for disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), and for other violations of state and federal law. The jury found in favor of plaintiff on certain state law claims and in favor of the employers on all other claims. The court concluded that the district court correctly applied a but-for causation standard to plaintiff's ADA claim; the court rejected plaintiff's claim that the district court erred in instructing the jury where the "prevents or significantly restricts" standard is too demanding under the ADA Amendments Act, Pub. L. No 110-325, section 5; even if the court assumes that the district court’s instruction was erroneous and that the error was plain, plaintiff has not shown that it affected her substantial rights; and the court rejected plaintiff's contention that the district court erred in instructing the jury on the “regarded as” prong of the definition of disability because she failed to show how she was prejudiced. Therefore, the court found no abuse of discretion and no serious prejudice to plaintiff that warrants vacating the verdict on her disability discrimination claims. Further, the court rejected plaintiff's challenge to the district court’s instruction on “record of” disability where she did not object to the instruction and on appeal did not explain how the omitted language applies to her case. Finally, the court rejected plaintiff's challenges to the damages the jury awarded on her state law claim. Accordingly, the court affirmed the judgment. View "Gentry v. East West Partners Club" on Justia Law

Appellants appealed a district court order granting summary judgment against them in their claims challenging the constitutionality of certain contribution limits established by the Federal Election Campaign Act of 1971 (FECA), see 52 U.S.C. 30101–30146. The court concluded that two of the three claims became moot before the district court granted summary judgment, and the court therefore vacated the merits judgment on those counts and remanded to the district court with instructions to dismiss them for lack of subject-matter jurisdiction. In Count III the Fund and ARCC challenge the constitutionality of the annual $5,000 limit that applies to contributions from “multicandidate political committee” (MPCs) to state political party committees and their local affiliates, and the Fund challenges the constitutionality of the annual $15,000 limit on contributions from MPCs to national party committees. The court concluded that, because appellants cannot demonstrate that FECA discriminates against MPCs, there is no discrimination to be justified, and the court concluded that the FEC was entitled to summary judgment on Count III. Accordingly, the court affirmed in part, vacated in part, and remanded in part with instructions to dismiss. View "Stop R.E.I.D. v. Federal Election Commission" on Justia Law

Plaintiffs filed suit against the City, alleging that the City, acting through it's Board of Zoning Appeals (BZA), violated the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., by denying plaintiffs' request for a variance to permit a certain property to be used as a church facility. The district court dismissed the complaint with prejudice. The court concluded that plaintiffs failed to state a claim that the BZA’s decision imposed a substantial burden on plaintiffs’ right of religious exercise. The court also concluded that the district court did not abuse its discretion in denying plaintiffs’ request to amend their complaint, because any such amendment would have been futile. Accordingly, the court affirmed the judgment. View "Andon, LLC v. The City of Newport News, VA" on Justia Law

Maryland allows any voter to vote via absentee ballot. Plaintiffs filed suit under Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12132, and Section 504 of the Rehabilitation Act, 29 U.S.C. 794, against state election officials under federal law, alleging that marking a hardcopy ballot by hand without assistance is impossible for voters with various disabilities, and that they have therefore been denied meaningful access to absentee voting. Defendants argue that even if absentee voting is not fully accessible, the full accessibility of Maryland’s in-person polling places provides disabled voters with meaningful access to voting. The court concluded that defendants’ proposed focus is overbroad and would undermine the purpose of the ADA and its implementing regulations. Therefore, the court affirmed the district court’s conclusion that by effectively requiring disabled individuals to rely on the assistance of others to vote absentee, defendants have not provided plaintiffs with meaningful access to Maryland’s absentee voting program. The court also concluded that plaintiffs’ proposed use of the online ballot marking tool is a reasonable modification to Maryland’s absentee voting policies and procedures. The court agreed with the the district court that defendants have not met their burden to show that plaintiffs’ proposed modification - use of the online ballot marking tool - would fundamentally alter Maryland’s voting program. Accordingly, the court affirmed the judgment. View "National Federation of the Blind v. Lamone" on Justia Law

Plaintiffs filed suit challenging Maryland's Firearm Safety Act (FSA), Md. Code, Crim. Law 4-303(a), which, among other things, bans law-abiding citizens, with the exception of retired law enforcement officers, from possessing the vast majority of semi-automatic rifles commonly kept by several million American citizens for defending their families and homes and other lawful purposes. The court concluded that the FSA implicates the core protection of the Second Amendment and the court, pursuant to District of Columbia v. Heller, McDonald v. City of Chicago, and its own precedent, concluded the burden is substantial and strict scrutiny is the applicable standard of review for plaintiffs’ Second Amendment claim. Therefore, the court vacated the district court's denial of these claims and remanded for the district court to apply strict scrutiny. The court affirmed the district court's denial of plaintiffs' equal protection challenge to the statutory exception allowing retired law enforcement officers to possess prohibited semi-automatic rifles. Finally, the court affirmed the district court’s conclusion that the term “copies” as used by the FSA is not unconstitutionally vague. View "Kolbe v. Hogan, Jr." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against two former members of the North Carolina Army National Guard, Adjutant General William E. Ingram, and Lieutenant Colonel Peter von Jess, alleging that defendants violated his Fourth Amendment rights. Plaintiff claimed that defendants, motivated by revenge, directed other service members to monitor plaintiff’s email messages, which he sent while serving on active duty in Kuwait, and to forward incriminating messages to von Jess. The district court granted summary judgment in favor of defendants based on the justiciability doctrine in Mindes v. Seaman. Mindes provided a four-factor test for reviewability of claims based on internal military affairs. The court acknowledged that defendant now renounces any claim for equitable relief and affirmed the district court's judgment on the basis of the military abstention doctrine set forth in Feres v. United States. In this case, plaintiff's alleged injuries arose out of activity incident to his service where he was on active duty, deployed in a war zone, and used a computer system set up by the DOD for military personnel deployed at Camp Doha. View "Aikens v. Ingram, Jr." on Justia Law

Plaintiffs filed suit arguing that Virginia's certificate of need (CON) law, a program that governs the establishment and expansion of certain medical facilities inside the state, unconstitutionally violates the dormant aspect of the Commerce Clause. The district court granted summary judgment to the Commonwealth. The court rejected plaintiffs' argument that Virginia’s CON requirement violates the dormant Commerce Clause by discriminating against interstate commerce in both purpose and effect, and rejected plaintiffs' argument that even if the program does not unconstitutionally discriminate, it nevertheless violates the dormant Commerce Clause because it places an undue burden on interstate commerce. Because the certificate requirement neither discriminated against nor placed an undue burden on interstate commerce, the court affirmed the judgment of the district court. View "Colon Health Ctrs. v. Hazel" on Justia Law

This appeal stems from multi-district litigation involving transvaginal mesh medical devices used to treat pelvic organ prolapse and other pelvic issues. The jury awarded plaintiff $250,000 in compensatory damages, and the punitive damages award was split pursuant to a Georgia statute, with seventy-five percent going to the State of Georgia and twenty-five percent going to plaintiff. Both parties appealed. The court affirmed the district court's exclusion of evidence that Bard had complied with the FDA's 510(k) product safety process under F.R.E. 402 for lack of relevance; affirmed the district court's decision to admit evidence of a material data safety sheet pertaining to polypropylene, a material used in the construction of the Avaulta Plus implanted in plaintiff's body, as non-hearsay, finding that any use of the evidence by plaintiff that went beyond the limited purpose for which it was admitted as non-hearsay resulted in harmless error and was not prejudicial to Bard’s defense; and concluded that the district court did not err in giving the Georgia pattern jury instruction, in denying Bard’s request for a modified instruction, or in upholding the jury’s causation finding. The court also concluded that the punitive award was not constitutionally excessive. In regard to plaintiff's challenges, the court affirmed the district court's conclusion that Georgia's split-recovery statute garnishing seventy-five percent of any punitive damages award arising from a product liability judgment does not violate the Takings Clause of the Fifth Amendment. Accordingly, the court affirmed the judgment. View "Cisson v. C. R. Bard, Inc." on Justia Law