Justia Constitutional Law Opinion Summaries

Three federal contractors sought a declaration that 2 U.S.C. 441c abridged their freedom of speech guaranteed by the First Amendment and denied them the equal protection of the laws in violation of the Fifth Amendment. FECA prohibited any "person" contracting with the federal government from contributing to "any political party, committee, or candidate for public office or to any person for any political purpose or use" in a federal election. The court sua sponte vacated and remanded to the district court to comply with immediate procedures set forth in section 437h, concluding that FECA's judicial review provision ousted both the district court and the court's jurisdiction to consider the merits of the claims. View "Wagner, et al. v. Federal Election Commission" on Justia Law

In an effort to reduce gun trafficking from the United States to Mexico, the ATF issued a demand letter under 18 U.S.C. 923(g)(5)(A) to a number of federal firearms licensees (FFLs) requiring each recipient making two or more sales of a specific firearm to the same buyer within five business days to file a report with the ATF. NSSF challenged the demand letter, arguing that ATF lacked statutory authority to issue it and that ATF acted in an arbitrary and capricious manner in selecting which FFLs were subject to it. The court rejected both arguments and affirmed the district court's grant of summary judgment to ATF. View "Nat'l Shooting Sports Found., et al. v. Jones" on Justia Law

Appellant, sentenced to prison for crimes involving powder and crack cocaine before Congress and the Sentencing Commission took steps to reduce the disparity in sentencing ranges between the two, sought declaratory and injunctive relief and possible damages after these efforts were directed at crimes involving lesser amounts of cocaine than his. The district court dismissed his suit on the ground that the only relief available to appellant was in habeas. Adopting Wilkinson v. Dotson's habeas-channeling rule, the court held that a federal prisoner need bring his claim in habeas only if success on the merits would "necessarily imply the invalidity of confinement or shorten its duration." Appellant's claim for declaratory relief avoided the habeas-channeling rule the court announced and its dismissal was improper. The court also concluded that the district court had jurisdiction to take up the merits of appellant's Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics claim because it was not based on plainly fictitious allegations and his pleading errors could be corrected through the liberal construction or amendment the court was accustomed to providing a pro se prisoner. Accordingly, the court reversed the district court's dismissal of appellant's complaint and remanded for further proceedings. View "Davis v. U.S. Sentencing Commission" on Justia Law

Appellants - AFGE, several AFGE locals that represent Air Reserve Technicians (ARTs), and ART Mark Winstead - challenged three Air Force instructions requiring ARTs to wear military uniforms while performing civilian duties. The district court dismissed the complaint for lack of subject matter jurisdiction because appellants failed to exhaust their administrative remedies under the Civil Service Reform Act of 1978 (CSRA), 5 U.S.C. 1101 et seq. The court affirmed the district court's dismissal because the exclusive remedial scheme of the CSRA precluded AFGE's claims. View "American Federation of Government Employees, et al v. Secretary of the Air Force" on Justia Law

Appellant, confined at St. Elizabeths Hospital since 1982, asserted a cause of action under, inter alia, 42 U.S.C. 1983, and alleged that DMH had violated his rights by seizing money from his patient account without affording him procedural due process. DMH responded that the hospital had lawfully transferred appellant's money to cover the cost of his care. It was clear from the record that appellant received proper notice before his funds were taken. The court also found that appellant's claim that he was denied due process lacked merit because he failed to invoke the remedies available to him under the D.C. Administrative Procedure Act, D.C. Mun. Regs. tit. 22-A, 308.9. Accordingly, the court affirmed the judgment. View "English v. District of Columbia, et al" on Justia Law

Appellants, holders of senior notes issued by Washington Mutual - a failed bank - sought to intervene in litigation between Deutsche Bank, the FDIC (Washington Mutual's receiver), and J.P. Morgan Chase. The district court denied intervention under Rule 24. The court concluded that appellants lacked Article III standing and affirmed the district court's denial of intervention. View "Deutsche Bank National Trust v. FDIC, et al" on Justia Law

Plaintiff alleged that her employer denied her a promotion and a transfer in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq., and the Age Discrimination in Employment Act of 1967, 29 U.S.C. 621 et seq. The district court granted summary judgment for the government. The court concluded that plaintiff had produced sufficient evidence that, when taken together, could lead a reasonable jury to conclude that the Secretary's proffered reason for cancelling the Lead Developmental Disabilities Specialist position plaintiff was seeking was pretext for racial discrimination. However, the court affirmed the district court's grant of summary judgment for the government on the Executive Assistance detail claim because plaintiff failed to make a showing that the government's proffered explanation was pretext for racial discrimination. Accordingly, the court reversed in part and affirmed in part. View "Evans v. Sebelius" on Justia Law

Plaintiff appealed the district court's grant of summary judgment against her claims of age and sex discrimination in the workplace. The district court credited the defense of plaintiff's employer that she was let go during a restructuring of the firm only because her expertise was not a good fit with the firm's new business focus. Viewing the facts in the light most favorable to plaintiff - including a productivity spreadsheet that included the age of each employee - the court concluded that a reasonable jury could find the employer's defense to be a pretext for discrimination. Therefore, the court reversed the judgment of the district court and remanded for further proceedings. View "Barnett v. PA Consulting Group, Inc." on Justia Law

Agreeing with the Board, the district court ruled that Quantum's 1996 Management Agreement with the Pueblo was null and void for lack of approval by the Secretary as required by 25 U.S.C. 81, and that it was incapable of being validated by the 2000 amendment to section 81, the application of which would be impermissibly retroactive. Applying Landgraf v. USI Film Products, the court concluded that Congress made no clear statement that it intended the 2000 amendment to apply retroactively. The court also concluded that, because the 1996 Agreement required Secretarial approval that was never obtained and the parties agreed that the Agreement would be valid without Secretarial approval under section 81 as amended, the application of the new law would give life to a null and void agreement, thereby attaching new legal consequences to it. Although the Pueblo may have voluntarily undertaken the stated duties and liabilities under the Agreement, such an agreement was null and void without Secretarial approval before 2000. Since the Secretary never approved the Agreement, any legislative validation of the duties or liabilities attached to it was impermissibly retroactive. Accordingly, the court affirmed the grant of summary judgment. View "Quantum Entertainment Ltd. v. Dept. of the Interior" on Justia Law

Defenders sued the EPA based on the EPA's alleged failure to promptly promulgate revisions to certain effluent limitations and effluent limitations guidelines under the Clean Water Act (CWA), 33 U.S.C. 1251 et seq. UWAG, an association of energy companies and three national trade associations of energy companies, appealed the denial of intervention and also asserted that the court should vacate the district court's order entering a consent decree between Defenders and the EPA because the district court lacked subject matter jurisdiction. The court affirmed the denial of intervention because UWAG lacked Article III standing and, as there was no appellant with standing, dismissed the remainder of the appeal. View "Defenders of Wildlife, et al v. Jackson" on Justia Law