Justia Constitutional Law Opinion Summaries

Plaintiffs brought suit challenging the constitutionality of section 5 of the Voting Rights Act (VRA), 42 U.S.C. 1973c, arguing that, as amended by the VRA's 2006 reauthorization, section 5 exceeded the powers granted to Congress by the Reconstruction Amendments and violated the Fifth Amendment's equal protection guarantee. The district court initially dismissed the suit for lack of standing but the court reversed and remanded based on the standing of plaintiff John Nix, who had announced his intention to run for the Kinston City Council in the 2011 elections. On remand, the district court granted summary judgment for the government, holding that section 5 was constitutional. While the appeal was pending before the court, and before oral argument could take place, the Justice Department changed its mind in light of some new evidence that it received in a separate proceeding. The Department subsequently informed the court and the parties that the Attorney General was withdrawing his objection to the proposed change. Three days later, the government filed its merits brief arguing in part that the case had been mooted by the Attorney General's actions. After considering the supplemental briefing from both parties, the court agreed with the government and therefore vacated the judgment and remanded the case to the district court with instructions to dismiss for lack of jurisdiction.

Plaintiff applied for a position as Director of the Library of Congress and when he was passed over for the job, he claimed that the Library of Congress violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. On appeal, defendant sought a new trial, arguing that the district court erred by instructing the jury that he had to prove that unlawful discrimination was the "sole reasons" for his non-selection. Although the court agreed that "sole reason" was not the correct standard, the jury instructions themselves corrected any error by defining "sole reasons" as "but-for" causation. The court recognized, however, that its recent Title VII employment discrimination cases have caused some confusion and the court took the opportunity to clarify the requirements the statute placed upon plaintiffs and the courts.

Plaintiffs, individuals claiming to be the Tribal Council of the Timbisha Shoshone, argued that the Western Shoshone Claims Distribution Act, Pub. L. No. 108-270, section 3, 118 Stat. 805, 806, was an unconstitutional taking of tribal property. The district court granted the Government's motion to dismiss, holding that the Distribution Act was constitutional. Plaintiffs appealed. The court concluded that plaintiffs lacked standing where the court had a letter from the Executive Branch recognizing the Gholson faction, not Kennedy faction, and therefore, the court did not reach the merits. Accordingly, the court vacated the judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction.

Defendant pled guilty to conspiracy to provide material support to a foreign terrorist organization. On appeal, defendant sought to vacate her sentence and remand the case for a new arraignment. The court rejected defendant's contention that her constitutional rights were violated because she did not enter into her plea knowingly and intelligently, and that she did not receive Spanish translations of all the documents in the case. Finding no error in the district court's acceptance of her plea, the court affirmed the conviction.

Taxpayer appealed a judgment of the Tax Court rejecting two contentions: first, a constitutional claim that certain employees of the IRS's Office of Appeals were "Officers of the United States," so that their appointments must conform to the Constitution's Appointments Clause, art. II, section 2, cl. 2, and second, an argument that the employees in question abused their discretion in rejecting his proposed compromise of the collection of his tax liability. Because the authority exercised by the Appeals Office employees whose status was challenged here appeared insufficient to rank them even as "inferior Officers," the court rejected the constitutional claims. Furthermore, the court found no abuse of discretion in those employee's decision in this case.

Plaintiffs brought an action arising under 42 U.S.C. 1983 against a number of MPD law enforcement personnel, asserting, inter alia, that various officers and their supervisors violated plaintiffs' Fourth Amendment rights by planning and conducting a 4:00 a.m. search on a warrant that did not authorize a nighttime search and breaking and entering into plaintiffs' home without knocking and announcing their presence. At issue on appeal was whether the district court erred in denying defendants qualified immunity on the knock-and-announce and nighttime search claims. The court agreed that defendants were entitled to qualified immunity because neither their no-knock entry of plaintiffs' home nor their nighttime search violated clearly established law. Therefore, the court reversed and remanded.

Plaintiffs, owners of two dairy operations, appealed the dismissal of their constitutional challenges to two provisions of the Milk Regulatory Equity Act of 2005 (MREA), 7 U.S.C. 608c. Plaintiffs alleged that the provisions, which subjected certain large producer-handlers of milk to contribution requirements applicable to all milk handlers, constituted a bill of attainder and violated the Equal Protection and Due Process Clauses. Because the court found that the MREA did not apply with specificity to affected persons, the court need not address whether it satisfied either of the remaining elements of a bill of attainder. Therefore, the court affirmed the district court's dismissal of plaintiffs' claim. In regards to plaintiffs' remaining arguments, the court held that mere disparity of treatment was not sufficient to state an equal protection violation. The court also found that the government provided an explanation that was not only rational on its face but also had been consistently recognized by the courts as legitimate. Further, plaintiffs failed to plead the threshold requirement of a due process claim: that the government had interfered with a cognizable liberty or property interest. Finally, the court found that the district court did not abuse its discretion by refusing to allow plaintiffs to file a supplemental complaint. Accordingly, the court affirmed the judgment of the district court.

Plaintiff sued United States Attorney General Eric Holder, alleging that the FBI refused to hire him as a special agent because of his Type I diabetes in violation of the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq. A jury found in favor of plaintiff and awarded him compensatory damages. Subsequently, the district court denied both Holder's motion for judgment as a matter of law and plaintiff's request for equitable relief. Both parties appealed. The court held that a reasonable jury could reasonably conclude that plaintiff's diabetes and treatment regiment "substantially limited" his major life activity of eating and that plaintiff was therefore disabled within the meaning of the Act. Rejecting the remaining arguments, the court held that the district court did not err in denying Holder's motion for judgment as a matter of law. The court also affirmed the district court's denial of equitable relief to plaintiff and rejected plaintiff's assertion that the district court erred in denying him front pay or instatement based on Holder's after-acquired evidence defense and in determining that plaintiff was not entitled to back pay based on the testimony of Holder's expert witness.

Plaintiffs, parents of children who were eligible to receive a free and appropriate public education, filed suit to challenge the exclusion of mapping of cochlear implants from the regulatory definition of "related services" under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1401(26)(B). The court concluded that the phrase "audiology services" as used in the IDEA's "related services" definition did not unambiguously encompass mapping of cochlear implants. The court also found that the Mapping Regulations embodied a permissible construction of the IDEA because they were rationally related to the underlying objectives of the IDEA. The court further found that the Mapping Regulations did not substantially lessen the protections afforded by the 1983 regulations. Because the Department's construction of its own regulation was neither plainly erroneous nor inconsistent with the regulation, the court owed it deference. Accordingly, the court affirmed the district court's grant of summary judgment to the Department.

Between defendant's first and second trials, he filed a pro se complaint alleging that federal officials violated the Fourth Amendment by conducting warrantless searches of his apartment and a warehouse leased in his name. On May 28, 2008, after defendant's conviction in the second trial, the district court dismissed his civil case sua sponte under Heck v. Humphrey. More than eight months after that dismissal, on January 31, 2009, defendant filed a document in the district court styled as a "Motion for Leave to File Notice of Appeal pro se by Plaintiff" (January Motion). The district court denied defendant leave to file the January Motion and he responded by filing a document he styled a "Notice of Appeal," which stated that he wished to obtain review of the denial of the January Motion. The court determined that defendant was appealing the district court's denial of leave to file a notice of appeal, and therefore deemed defendant's filing a petition for mandamus. The court held that mandamus was unwarranted because the district court properly denied defendant leave to file. Accordingly, the court denied defendant's petition for mandamus.