Justia Constitutional Law Opinion Summaries

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

The Estate of Ronald H. Armstrong appealed the district court's grant of summary judgment to the Village and members of the police department on its excessive force claims. The court held that defendants used unconstitutionally excessive force when seizing Armstrong. Had defendants limited themselves to permissible uses of force when seizing Armstrong, they would have had every tool needed to control and resolve the situation at their disposal. However, the court concluded that defendants are entitled to qualified immunity where Armstrong’s right not to be tased while offering stationary and non-violent resistance to a lawful seizure was not clearly established. Accordingly, the court affirmed the judgment. View "Estate of Ronald Armstrong v. The Village of Pinehurst" on Justia Law

After plaintiff flunked out of the FBI Academy by failing to perform the required amount of push-ups, he filed suit under Title VII of the Civil Rights Act, 42 U.S.C. 2000e-16(c). Plaintiff alleged that the FBI discriminated against him on the basis of sex, in that female New Agent Trainees were required to complete only fourteen push-ups. The district court granted plaintiff's motion for summary judgment and the Attorney General appealed. The court held that an employer does not contravene Title VII when it utilizes physical fitness standards that distinguish between the sexes on the basis of their physiological differences but impose an equal burden of compliance on both men and women, requiring the same level of physical fitness of each. Because the FBI purports to assess physical fitness by imposing the same burden on both men and women, this rule applies to plaintiff’s Title VII claims. The court concluded that the district court erred in failing to apply the rule in its disposition of plaintiff's summary judgment motion. Accordingly, the court vacated the judgment and remanded for further proceedings. View "Bauer v. Lynch" on Justia Law

Plaintiff filed suit under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b), against the United States, alleging that prison officials had been negligent in failing to protect him from an attack by several other inmates. The district court granted the government’s motion to dismiss for lack of subject matter jurisdiction. The district court granted the government’s motion to dismiss for lack of subject matter jurisdiction. The court affirmed the district court’s holding that the prison officials’ discretionary decision not to separate plaintiff from his attackers is subject to the discretionary function exception of the FTCA, depriving the court of jurisdiction over that claim. In regard to plaintiff's claim that prison officials did not perform the searches properly, the court remanded for additional discovery because jurisdictional facts are intertwined with the merits of that claim. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Rich v. United States" on Justia Law

The County petitions for review of an FCC order, which issued rules implementing Section 6409(a) of the Middle Class Tax Relief and Job Creation Act of 2012, 47 U.S.C. 1455(a), also known as the Spectrum Act. The County contends that the procedures established in the Order conscript the states in violation of the Tenth Amendment, and that the Order unreasonably defines several terms of the Spectrum Act. The court concluded that the FCC’s “deemed granted” procedure comports with the Tenth Amendment where the Order does not require the states to take any action whatsoever. The court also concluded that the FCC has reasonably interpreted the ambiguous terms of Section 6409(a): "substantially change" and "base station." Accordingly, the court denied the petition for review. View "Montgomery County v. United States" on Justia Law

Plaintiff collapsed with exertional heatstroke while practicing as a member of the Towson University football team. Plaintiff was in a coma for nine days, almost died, and suffered multi-organ failure, requiring a liver a transplant and numerous additional surgeries. Plaintiff subsequently recovered and pursued his plan to return to playing football. However, the Team Physician, a board-certified sports medicine doctor, concluded that allowing plaintiff to participate in the football program at the University presented an unacceptable risk of serious reinjury or death. Plaintiff filed suit against the University, alleging that its decision to exclude him from the football program amounted to a violation of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. 701 et seq. The district court entered judgment against the University. The court reversed, concluding that plaintiff was not “otherwise qualified” to participate fully in the University’s football program because the University reasonably applied its Return-to-Play Policy. The court was required to give deference to the University's judgment. The court did not reach the University's challenge to the district court's evidentiary rulings. View "Class v. Towson Univ." on Justia Law

Plaintiff filed suit against the police department and three of its former detectives for damages under 42 U.S.C. 1983, alleging that the police and prosecution withheld evidence in violation of Brady v. Maryland during plaintiff's 1982 murder trial. The district court dismissed the case under Heck v. Humphrey. The court affirmed the judgment, concluding that this case involves section 1983 claims that are predicated on alleged Brady violations which would, if proven, necessarily imply the invalidity of plaintiff's convictions. Those convictions have not been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal, or called into question by a federal court's issuance of a writ of habeas corpus. Therefore, under Heck, they may not be collaterally attacked through section 1983 now. The court concluded that the fact that plaintiff is no longer in custody does not change this result. Finally, plaintiff has identified no impediment to habeas access warranting an expansion of the Heck exception. View "Griffin v. Baltimore Police Dept." on Justia Law