Justia Constitutional Law Opinion Summaries

Plaintiffs filed a class action against ARS, a debt collection agency, under the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. 1692 et seq. The class consists of some four million people nationwide. At issue is whether the magistrate judge had the authority to exercise jurisdiction to approve the class action settlement without obtaining the consent of all four million class members. If so, at issue is whether the magistrate judge abused her discretion by approving the settlement as fair, reasonable, and adequate. The court concluded that the magistrate judge had the authority to enter final judgment pursuant to 28 U.S.C. 636(c); the court joined three of its sister circuits and concluded that the statute requires the consent of the named plaintiffs alone, not the consent of the four million class members not present before the district court; and section 636(c) does not violate Article III of the Constitution by permitting magistrate judges to exercise jurisdiction over class actions without obtaining the consent of each absent class member. The court concluded that the magistrate judge abused her discretion by approving the settlement because there is no evidence that the relief afforded by the settlement has any value to the class members, yet to obtain it they had to relinquish their right to seek damages in any other class action. Furthermore, ARS and the named plaintiffs likewise presented no evidence that the absent class members would derive any benefit from the settlement’s cy pres award. Therefore, the court reversed and remanded. View "Koby v. Helmuth" on Justia Law

This case arose out of a dispute between a flight attendant and the airline about her sick leave. Plaintiff claimed an entitlement to use her December vacation leave for her child’s illness without being charged points, under the Washington Family Care Act, Wash. Rev. Code 49.12.270(1). The Department determined that plaintiff was entitled to use her December vacation leave to care for her child in May, and the airline was fined $200 for violating the statute. The district court subsequently granted summary judgment against the airline’s preemption claim under the Railway Labor Act (RLA), 45 U.S.C. 151-188. The court concluded that the state law right and the collective bargaining agreement are inextricably intertwined. Minor disputes are preempted by the RLA and must be dealt with first through a carrier’s internal dispute resolution process, and then a System Adjustment Board comprised of workers and management. In this case, the court concluded that the question whether plaintiff could use her vacation leave in advance of her scheduled time for this purpose is to be determined by the dispute resolution process in the collective bargaining agreement, not by the state claim resolution process. Because the district court erred by rejecting preemption, the court reversed and remanded. View "Alaska Airlines, Inc. v. Schurke" on Justia Law

Plaintiff filed suit challenging the procedure for contesting parking citations pursuant to the California Vehicle Code. Plaintiff filed a putative class action against various city officials alleging 42 U.S.C. 1983 claims for due process violations, malicious prosecution, conspiracy, and Monell liability, as well as a claim under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961 et seq. The district court dismissed plaintiff's claims with prejudice. The court rejected plaintiff's claim for violation of procedural due process based on the Code's deposit requirement given the availability of prompt post-deprivation review and correction. The court explained that plaintiff's modest interest in temporarily retaining the amount of a parking penalty is outweighed by the City’s more substantial interests in discouraging dilatory challenges, promptly collecting penalties, and conserving scarce resources. The court also rejected plaintiff's substantive due process challenge, concluding that plaintiff has failed to allege conduct so egregious as to amount to an abuse of power lacking any reasonable justification in the service of a legitimate governmental objective. Because plaintiff has not alleged a violation of his constitutional rights, he cannot maintain derivative constitutional claims based on that conduct. The court rejected plaintiff's remaining claims and agreed with the district court's denial of leave to amend based on futility. Accordingly, the court affirmed the judgment. View "Yagman v. Garcetti" on Justia Law

Dr. Lawrence P. Rudolph filed suit against SCI after various SCI members accused him of official misconduct, stripped him of his awards, and kicked him out of the association. Rudolph surreptitiously recorded a conversation with his friend John Whipple, SCI's president, and posted it on YouTube to exonerate himself. Whipple and SCI filed numerous claims against Rudolph, including statutory invasion of privacy, negligence per se, and common law invasion of privacy. The district court granted Rudolph’s motion to strike under California’s anti-SLAPP statute, Cal. Civ. Proc. Code 425.16, as to four claims, but denied relief as to three claims. Rudolph appeals. The court concluded that the district court correctly denied Rudolph's motion as to the claims for violation of California Penal Code section 632, negligence per se, and common law invasion of privacy. In this case, although Rudolph can show that those claims arise from activity he took in furtherance of his right to free speech, plaintiffs can show a reasonable probability of prevailing on each of the challenged claims. Accordingly, the court affirmed the judgment; denied Rudolph's corresponding request for an additional attorney fee award; and remanded for further proceedings. View "Safari Club International v. Rudolph" on Justia Law

After Nóirín Plunkett accused Michael Schwern of raping her and he was arrested, he filed suit against Plunkett for defamation, intentional infliction of emotional distress, and intentional interference with economic relations. Plunkett filed a special motion to strike under Oregon’s anti-SLAPP law, Or. Rev. Stat. 31.152(4), but the district court denied the motion. The court held that it has jurisdiction to review denials of Oregon anti-SLAPP motions in light of Oregon's passage of amendments to create a right of immediate appeal from denials of anti-SLAPP motions. On the merits, the court concluded that a reasonable trier of fact could not find that Schwern met his burden of production to support a prima facie case with substantial evidence. Because Schwern failed to establish a prima facie case through substantial evidence, Plunkett was entitled to relief under Oregon’s anti-SLAPP law. Accordingly, the court reversed and instructed the district court to grant the motion to strike. View "Schwern v. Plunkett" on Justia Law

Plaintiff filed suit against King County and King County Sheriff's Deputies, under 42 U.S.C. 1983, alleging, inter alia, that Deputy Volpe violated her Fourth Amendment rights by arresting her without probable cause, conducting an unreasonable seizure, using excessive force during the arrest, and conducting an unlawful search of her truck. Deputies Volpe, Sawtelle, and Christian appealed the district court’s denial of qualified immunity on the excessive force and unlawful search claims. The court concluded that the deputies are entitled to qualified immunity in this case because the government's interests at stake - providing life-saving emergency medical care and to protect first responders and other motorists from potential harm - outweighed any intrusion on plaintiff's Fourth Amendment rights. The court thought that Deputy Volpe’s use of force in this case was reasonable in response to the totality of the circumstances. Furthermore, Deputies Sawtelle and Christian did not violate plaintiff's Fourth Amendment rights when they searched her truck in an attempt to find the medications plaintiff's son had ingested in his overdose. Accordingly, the court reversed and remanded for entry of dismissal. View "Ames v. King County" on Justia Law

Pure Wafer, a facility that cleans silicon wafers, filed suit against the City, challenging Ordinance No. 4856-1313. The Ordinance imposes limits on the pollutants that industrial users, like Pure Wafer, are permitted to discharge into the City’s sewer system. Pure Wafer claims that by enacting the Ordinance, the City impaired the obligation of its contract with Pure Wafer and committed at least two different breaches of contract. The district court entered judgment for Pure Wafer and awarded Pure Wafer a permanent injunction. The court concluded that the City has not impaired the obligation of its contract with Pure Wafer in violation of the Contracts Clause of the Constitution, because the Ordinance has not altered the ordinary state-law remedies to which Pure Wafer would otherwise be entitled if it successfully proves a breach of contract. The court explained that the City might very well have breached its contract but that does not necessarily mean it has violated the Contracts Clause. Therefore, the court reversed as to the Contracts Clause claim. The court agreed, however, with Pure Wafer's alternative claim that the City has breached the contractual obligations it undertook in the Development Agreement. In this case, the City agreed to accept such effluent as the parties knew Pure Wafer would need to discharge in order to maintain a viable business, and the City agreed to bear the financial risk that State-initiated regulatory changes would make complying with such promise more costly than it was when the parties entered into the Agreement. Therefore, the court concluded that the City may not force Pure Wafer to absorb the costs needed to bring the City into line with the terms of its Aquifer Protection Permit. The court explained that enforcing the Ordinance against Pure Wafer would eviscerate the benefit of Pure Wafer’s bargain; the City cannot do so without putting itself in breach of the Agreement. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Pure Wafer Inc. v. City of Prescott" on Justia Law

Plaintiff, an Arizona state prisoner and former pretrial detainee, filed suit pro se under 42 U.S.C. 1983, challenging defendants' alleged policy of allowing female guards to observe daily, from four to five feet away, male pretrial detainees showering and using the bathroom. The district court dismissed the complaint under 28 U.S.C. 1915A, concluding that Ninth Circuit precedent foreclosed plaintiff's claims. The court concluded that the fact that plaintiff is a pretrial detainee is enough to distinguish his allegations from precedent concerning convicted prisoners; even if plaintiff were a convicted prisoner, plaintiff's allegations survive section 1915A dismissal because the scope and manner of the intrusions were far broader than those the court previously has approved; the allegations of plaintiff's bodily privacy claim, taken as true, warrant an answer; and plaintiff's allegations for his cruel and unusual punishment claim, taken as true, are sufficient to meet the low threshold for proceeding past the screening stage. The court noted that it may be that the prison’s up close and personal policy of female guards observing male pretrial detainees is necessary to ensure security and provide equal work opportunities in the prison. The court explained that such considerations and their legal effect are just conjecture at this point. And conjecture is not enough to dismiss a complaint under section 1915A. Accordingly, the court reversed and remanded. View "Byrd v. Maricopa County Board of Supervisors" on Justia Law

Plaintiffs, the widow and children of the late spiritual leader of the Sikh Dharma faith, filed suit against defendants, alleging claims related to the control of two nonprofit entities associated with the Sikh Dharma religious community. Plaintiffs alleged several interlocking conspiracies and fraudulent activities designed to exclude them from certain management positions and to convert millions of dollars in assets from entities under the individual defendants’ control for personal benefit. The district court dismissed the complaint and concluded that plaintiffs' claims were foreclosed by the Free Exercise and Establishment Clauses of the First Amendment. The court concluded, however, that based on the pleadings, plaintiffs' claims are not barred by the First Amendment’s ministerial exception and can be resolved by application of neutral principles of law without encroaching on religious organizations’ right of autonomy in matters of religious doctrine and administration. For the reasons stated in this opinion and in the concurrently filed memorandum disposition, the court vacated in part, affirmed in part, and remanded. View "Puri v. Khalsa" on Justia Law

After Deanna Fogerty-Hardwick lost custody of her minor children, Preslie and Kendall, Preslie filed suit under 42 U.S.C. 1983 against the County and employees of the SSA. Preslie alleges that the social worker employees acting under color of state law maliciously used perjured testimony and fabricated evidence to secure her removal from her mother, and that this abuse of state power violated her Fourth and Fourteenth Amendment constitutional rights to her familial relationship with her mother. After the district court denied absolute and qualified immunity to the individual defendants, they appealed. The court affirmed the district court's denial of absolute immunity where Preslie’s complaint targets conduct well outside of the social workers’ legitimate role as quasi-prosecutorial advocates in presenting the case. The court concluded that Beltran v. Santa Clara County disposes of the issue. In Beltran, the court held that social workers are not entitled to absolute immunity from claims that they fabricated evidence during an investigation or made false statements in a dependency petition affidavit that they signed under penalty of perjury, because such actions are not similar to discretionary decisions about whether to prosecute. The court also concluded that defendants' use of perjured testimony and fabricated evidence in court in order to sever Preslie’s familial bond with her mother was unconstitutional. In this case, Preslie has produced more than sufficient admissible evidence to create a genuine dispute as to whether her removal from her mother’s custody violated her clearly established constitutional rights, and defendants’ case for qualified immunity from these charges is not supported by the law or the record. Accordingly, the court affirmed the judgment. View "Hardwick v. County of Orange" on Justia Law