Justia Constitutional Law Opinion Summaries

Under Michigan abortion law, a minor may bypass the parental-consent requirement by obtaining a court order granting the right to self-consent (for mature minors) or judicial consent (for “best interests” minors). When the plaintiff sought to apply for judicial bypass, the defendant hadn’t heard of the process and told the plaintiff to come back later. Plaintiff sued the defendant in her individual and official capacities under 42 U.S.C. § 1983, alleging that defendant’s refusal to allow her to apply for a judicial bypass without parental notification violated her Fourteenth Amendment rights. The district court denied the motion when the defendant moved for summary judgment, invoking quasi-judicial and qualified immunity.Before the Eighth Circuit, the defendant claimed she acted at the direction of the Associate Circuit Judge (“Judge”). The Judge testified that he did not recall telling the defendant not to accept the application without parental consent. The circuit court concluded there was a genuine issue of material fact regarding the Judge’s practice of giving pre-filing directions. Further, the is a clearly established right to apply for a judicial bypass. Thus the circuit court declined to address the defendant’s other arguments regarding qualified immunity. View "Jane Doe v. Michelle Chapman" on Justia Law

Defendant pleaded guilty to murdering his cousin and her husband. At sentencing, the defendant was represented by two attorneys with experience handling capital cases. The jury returned a sentence of death for each murder, finding seven aggravating factors beyond a reasonable doubt. Defendant then petitioned the district court for a writ of habeas corpus under Section 2254, raising twenty-eight claims, including a claim that his trial attorneys were ineffective for failing to investigate and present evidence of his adjustment to incarceration.The Eighth Circuit reviewed whether a claim of ineffective assistance of trial counsel is substantial under Martinez v. Ryan, 566 U.S. 1 (2012). Martinez requires a defendant to show that his underlying claim of ineffective assistance of trial counsel has “some merit.” The circuit court agreed with the defendant that the district court erred by treating the substantiality standard as different from the certificate-of-appealability standard. However, the court concluded that the error was harmless because the defendant’s ineffective-assistance claim was insubstantial even under the correct standard. The circuit court found that no reasonable jurist could believe that or find it debatable whether either prong of the defendant’s ineffective-assistance claim is met. Thus, the defendant cannot show cause for his failure to raise the claim in state postconviction proceedings. View "Brian Dorsey v. David Vandergriff" on Justia Law

Plaintiff alleges he was unlawfully assaulted, pepper-sprayed, detained in an unlawful mass arrest, and ultimately incarcerated. He sued the City of St. Louis and multiple police officers for First, Fourth, and Fourteenth Amendment violations, conspiracy to deprive him of civil rights, and supplemental state law claims. One officer moved to dismiss the 1983 claims, arguing plaintiff’s amended complaint failed to state a claim and he is entitled to qualified immunity. The only allegations relating to the defendant’s involvement are that he was working on September 17 and took custody of the plaintiff’s bicycle lying in the street at the time of his arrest. These allegations do not establish a causal link between the plaintiff and the specific wrongs the defendants as a whole allegedly committed. Further, the defendant is entitled to qualified immunity because the amended complaint did not contain specific and plausible allegations linking the defendant to overt acts alleged as part of the conspiracy of all the defendants. The assertion that he agreed to participate in those acts does not state a plausible claim.Finally, the circuit court held that the district court erred in denying the other defendants' motion to dismiss. The defendants are entitled to qualified immunity because the intracorporate conspiracy doctrine was not clearly established. View "Michael Faulk v. Gerald Leyshock" on Justia Law

Minnesota Governor Walz (“Walz”) signed an executive order mandating a statewide residential eviction moratorium. Heights Apartments, LLC (“Heights”), a property owner of residential units, challenged the executive orders, raising First Amendment, Fifth Amendment, and Fourteenth Amendment claims under Section 1983.The court found that the plaintiffs met the two-prong test to determine whether a state has impermissibly interfered with a contract. However, the court held that Heights has failed to allege a cognizable Petition Clause claim because the only potential remedy is damages; Heights has not pleaded damages that are somehow unique to its Petition Clause claim.Heights alleged it was deprived of its expected return on investment in the form of rental income. These alleged damages are sufficient to plausibly give rise to a Fifth Amendment takings claim. Finally, Heights has alleged violations of various rights that trigger protections under other constitution amendments; however, it has failed to plausibly plead a substantive due process violation. Thus, Heights has plausibly argued constitutional claims under the Contract Clause and Takings Clause. The court reversed the dismissal of those two claims and remanded for further proceedings. View "Heights Apartments, LLC v. Tim Walz" on Justia Law

Plaintiffs, employees of the University of Iowa Hospitals and Clinics sued the Iowa Board of Regents (“Board”), alleging state law claims. The Board removed the case to federal court after the plaintiffs amended their complaint to include a Fair Labor and Standards Act (“FLSA”) claim.The Board argued that the court lacked jurisdiction over the FLSA claim because the Board has sovereign immunity. The court reasoned that FLSA overtime isn’t guaranteed for Board of Regents employees. And because its own pay agreements don’t separately provide FLSA overtime standards, the Board hasn’t consented to private accountability to those standards. A private cause of action cannot work as express consent to suits under the FLSA itself. Iowa courts retain the doctrine of constructive waiver of sovereign immunity.Further, though the University of Iowa system may benefit from the Board’s immunity at times, the University lacks independent authority to abrogate it. Finally, the court remanded for the district court to consider whether the legal consequences of the hospital’s policies can be attributed to the Board. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Melinda Myers v. Iowa Board of Regents" on Justia Law

Defendant and nine others were charged with conspiring to sell methamphetamine between 2015 and 2019. The other nine co-defendants all pleaded guilty and cooperated with the government in Defendant's case. The prosecution sought admission of controlled buy in which Defendant sold methamphetamine to a confidential informant several months before the conspiracy began. The district court admitted the transaction with a limiting instruction. A jury found Defendant guilty, and the judge sentenced him to 130 months incarceration.The Eighth Circuit affirmed. The court held that the co-conspirators' statements against Defendant were admissible because the evidence “stemmed from reasonably foreseeable buys and aided in proving the extent of the conspiracy.” The court also found that evidence of the controlled buy was admissible under Fed. R. Evid. 404(b). Finally, the court concluded that the evidence was sufficient to support Defendant’s conviction and that the district court did not commit any error when calculating Defendant’s sentence. View "United States v. Travis Ferguson" on Justia Law

After a civilian reported a vehicle traveling the wrong way on the highway, a state trooper located Defendant driving a vehicle matching the description. The trooper, who had a K9 unit with him, initiated a traffic stop after noticing the vehicle’s tint appeared to violate state law. During the stop, the trooper discovered the defendant’s driver’s license was suspended. While the trooper was waiting for backup, he asked Defendant to consent to a K9 search of the vehicle. The defendant declined; however, relying on highway patrol protocol, the trooper proceeded with the K9 search. The K9 unit indicated the presence of narcotics, prompting the trooper to search the vehicle, where he discovered cocaine, methamphetamine and a firearm. A subsequent inventory search of the vehicle revealed two additional handguns and a small amount of methamphetamine. Several days later, the trooper performed a second inventory search, locating 459 grams of methamphetamine.The district court denied Defendant’s motion to suppress based on the prolonged nature of the initial traffic stop and various departures from highway patrol policy in conducting the inventory search.The Eighth Circuit affirmed, finding the traffic stop was not impermissibly extended due to the discovery of narcotics and a firearm. The court also held that the trooper substantially complied with departmental policy in conducting the inventory searches. Finally, the court rejected Defendant’s claim that the district court erred in denying his motion for a mistrial based on claims the prosecutor violated the prohibition against mentioning the defendant’s failure to testify. View "United States v. Jose Perez" on Justia Law

The Eighth Circuit reversed the district court's adverse grant of summary judgment in favor of Metro Transit in an action brought by plaintiff, who is blind and deaf, alleging claims under the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Minnesota Human Rights Act (MHRA). In this case, plaintiff's claims stemmed from 150 complaints he made regarding bus operators' failure to stop at T-Signs and announce the bus route. The court concluded that the record contains evidence sufficient to raise a genuine issue of material fact as to whether Metro Transit provided meaningful access to disabled bus riders. The court stated that, at trial, the DOT regulations cited by plaintiff are admissible as evidence that the jury may consider and weigh when determining whether he has met his burden of demonstrating that he was denied meaningful access to Metro Transit's services. View "Segal v. Metropolitan Council" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment in favor of Bi-State in an action brought by plaintiff under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The court concluded that the district court did not abuse its discretion in determining that plaintiff's claims regarding federal transportation regulations were barred by judicial estoppel where his position on summary judgment is inconsistent with the position he took on Bi-State's motion for a judgment on the pleadings; he persuaded the district court that he was not pursuing a private right of action under the federal regulations; and allowing him to take an inconsistent position would give him an unfair advantage in the litigation.The court rejected plaintiff's argument that the district court erred when it determined his claims were barred by the previous settlement agreement and, alternatively, granted summary judgment to Bi-State on the merits. The court concluded that, even assuming the agreement does not bar plaintiff's claims, those claims would still fail because he cannot demonstrate that Bi-State denied him meaningful access to its services. In this case, plaintiff has not shown he was denied an opportunity to access the same services as non-disabled riders. Finally, the court concluded that it lacked jurisdiction to review the denial of plaintiff's motion to amend the complaint. View "Gustafson v. Bi-State Development Agency" on Justia Law

After a jury found plaintiff not guilty of a drug trafficking offense, he filed a civil rights action against two police officers alleging they conspired to include false statements in an affidavit of probable cause executed shortly after his arrest.The Eighth Circuit affirmed the district court's grant of the motion to dismiss based on qualified immunity where the affidavit provided arguable probable cause for plaintiff's arrest even without the allegedly false statements at issue. The court concluded that the uncontested portions of the affidavit show officers knew at the time that plaintiff repeatedly had been with the targets of their investigation close in time to cocaine sales. Viewed in totality through the lens of common sense, the court stated that the affidavit with the alleged falsehoods removed still supports probable cause. The court affirmed the dismissal of all plaintiff's claims as they are derivative of the probable cause argument. View "Allen v. Monico" on Justia Law