Justia Constitutional Law Opinion Summaries

Plaintiff filed suit against the Sheriff's Department and others under 42 U.S.C. 1983 and Louisiana state law, alleging wrongful arrest, wrongful detention, and malicious prosecution.The Fifth Circuit vacated in part the district court's dismissal based on lack of subject matter jurisdiction, rendering judgment in favor of each defendant on each of the federal law claims. The court held that the magistrate judge erred in concluding that, if plaintiff's section 1983 claims were barred by limitations, subject matter jurisdiction over those claims was lacking. The court held that the section 1983 claims based on wrongful or false arrest and wrongful detention were time-barred, and the court declined to apply equitable tolling to the claims. The court also held that defendant inadequately briefed his malicious prosecution claim, and dismissal of the pendant state-law claims was within the district court's discretion. Accordingly, the court affirmed the judgment to the extent it dismissed plaintiff's state law claims. View "Bradley v. Sheriff's Department St. Landry Parish" on Justia Law

When a prison inmate engages in willful misconduct, a prison guard may use reasonable force to restrain him—but after the inmate submits, there is no need, and thus no justification, for the further use of force. Under Heck v. Humphrey, 512 U.S. 477 (1994), a convicted criminal may not bring a claim under 42 U.S.C. 1983, if success on that claim would necessarily imply the invalidity of a prior criminal conviction. An inmate cannot bring a section 1983 claim for excessive use of force by a prison guard, if the inmate has already been found guilty for misconduct that justified that use of force. However, Heck does not bar a section 1983 claim for a prison guard’s excessive use of force after the inmate has submitted and ceased engaging in the alleged misconduct.In this case, the Fifth Circuit held that Heck barred plaintiff's section 1983 claim as to the alleged use of force in his cell—but not as to the alleged use of force again later in the prison lobby and shower. Therefore, the court reversed the district court's dismissal of plaintiff's Heck claim and remanded for further proceedings. View "Aucoin v. Cupil" on Justia Law

After Phillip Garcia, Jr. was shot and killed by an officer, Garcia's parents filed suit against the officers for violation of Garcia's constitutional rights. The Fifth Circuit affirmed the district court's grant of summary judgment to the officer. The court held that, while the officer may have violated Garcia's right to be free from deadly force, the law was not clearly established at the time where it was undisputed that Garcia was aware of the officer's presence and that the officer ordered Garcia to put down his weapon, but Garcia refused to do so. View "Garcia v. Blevins" on Justia Law

In 2017, Texas enacted a law that forbids its governmental entities from contracting with companies who engage in economic boycotts of Israel. Plaintiffs, who support the Palestinian side of the conflict, filed two actions seeking declaratory and injunctive relief in federal district court, alleging that requiring "No Boycott of Israel" clauses in Texas government contracts violates the First Amendment. The district court then preliminarily enjoined the enforcement of the clauses in all contracts with Texas governmental entities.The Fifth Circuit held that the appeal is moot because, twelve days after the district court's ruling, Texas enacted final legislation that exempts sole proprietors from the "No Boycott of Israel" certification requirement. Because plaintiffs are no longer affected by the legislation, the court held that they lacked a personal stake in the outcome of this litigation. Accordingly, the court vacated the preliminary injunction order and remanded the case to the district court to enter an appropriate judgment dismissing the complaints. View "Amawi v. Paxton" on Justia Law

Plaintiffs filed suit against the Board over changes to their pension fund, alleging that limiting plaintiffs' ability to withdraw from their Deferred Retirement Option Plan (DROP) funds constituted an unlawful taking under the Fifth Amendment of the United States Constitution and violated article XVI, section 66, of the Texas Constitution, which prohibits reducing or otherwise impairing a person’s accrued service retirement benefits.The Fifth Circuit certified two questions to the Supreme Court of Texas, asking (1) whether the method of withdrawing DROP funds is a service retirement benefit protected under Section 66, and (2) whether the Board's decision to change the withdrawal method for plaintiffs' DROP funds violates Section 66. The Supreme Court of Texas held that (1) although plaintiffs' DROP funds are service retirement benefits protected by Section 66, the method of withdrawing DROP funds is not, and (2) the Board's decision to change the withdrawal method of plaintiffs' DROP accounts did not violate Section 66.In this case, the court held that plaintiffs failed to state a takings claim because they do not have a property interest in the method of withdrawing DROP funds, and thus the court affirmed the district court's dismissal of plaintiffs' takings claim. Furthermore, the court held that plaintiffs failed to plead a regulatory taking claim. Accordingly, the court affirmed the district court's dismissal for failure to state a claim. View "Degan v. Board of Trustees of the Dallas Police and Fire Pension System" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment to prison officials in a 42 U.S.C. 1983 action brought by plaintiff, an inmate in custody at the MDOC, alleging that defendants violated the Eighth and Fourteenth Amendments by being deliberately indifferent to the risk that another inmate would harm plaintiff. The court held that plaintiff's claims against defendants in their official capacities are barred under sovereign immunity.The court also held that the magistrate judge correctly granted summary judgment on plaintiff's theory that defendants failed to protect him from the other inmate, where there is no evidence in the record to suggest that defendants knew the inmate was a member of a gang or otherwise posed a specific threat to plaintiff when they moved him into plaintiff's zone. Furthermore, the magistrate judge correctly granted summary judgment on plaintiff's theory that defendants violated plaintiff's constitutional rights because they placed the inmate into plaintiff's protective custody zone instead of following MDOC policy and placing the inmate in lockdown. In this case, defendants did not disregard an excessive risk to inmate health or safety. View "Williams v. Banks" on Justia Law

Plaintiffs filed suit alleging that TDCJ's adoption and implementation of measures guided by changing CDC recommendations in regards to the COVID-19 pandemic do not go far enough. Plaintiffs filed a class action alleging violations of the Eighth Amendment's prohibition against cruel and unusual punishment, and the Americans with Disabilities Act, seeking a preliminary injunction.The Fifth Circuit granted TDCJ's motion to stay the district court's preliminary injunction, which regulates the cleaning intervals for common areas, the types of bleach-based disinfectants the prison must use, the alcohol content of hand sanitizer that inmates must receive, mask requirements for inmates, and inmates' access to tissues (amongst many other things). The court held that TDCJ is likely to prevail on the merits of its appeal because: (1) after accounting for the protective measures TDCJ has taken, plaintiffs have not shown a "substantial risk of serious harm" that amounts to "cruel and unusual punishment"; and (2) the district court committed legal error in its application of Farmer v. Brennan, by treating inadequate measures as dispositive of defendants' mental state. In this case, even assuming that there is a substantial risk of serious harm, plaintiffs lack evidence of defendants' subjective deliberate indifference to that harm. The court also held that TDCJ has shown that it will be irreparably injured absent a stay, and that the balance of the harms and the public interest favor a stay. Finally, the court held that plaintiffs have not exhausted their administrative remedies as required in the Prison Litigation Reform Act (PLRA), and the district court's injunction goes well beyond the limits of what the PLRA would allow even if plaintiffs had properly exhausted their claims. View "Valentine v. Collier" on Justia Law

After Diana Simpson died of a drug overdose while she was a pretrial detainee at the Young County Jail, her family filed suit under 42 U.S.C. 1983, alleging Eighth and Fourteenth Amendment violations, as well as a claim under the Texas Tort Claims Act. The Fifth Circuit previously affirmed summary judgment for the County in part, and remanded in part for the district court to evaluate plaintiffs' conditions-of-confinement theory in the first instance. On remand, the district court granted summary judgment on that theory and plaintiffs appealed.The court affirmed the district court's dismissal of plaintiffs' claims based on a failure to train based on the law-of-the-case doctrine. The court held that the district court erred in dismissing plaintiffs' claims based on a failure to monitor because plaintiffs' evidence, when viewed in the light most favorable to them, creates several disputes of material fact about whether the jail has a de facto policy of inadequately monitoring detainees. Furthermore, plaintiffs offered sufficient evidence to create fact issues over whether the County failed to assess pretrial detainees' medical needs and whether this caused plaintiff to be denied needed medical care. Accordingly, the court reversed in part and affirmed in part, remanding for further proceedings. View "Sanchez v. Young County" on Justia Law

Plaintiffs allege that for years, prosecutors at the Orleans Parish District Attorney's Office, under the direction of District Attorney Leon Cannizzaro, used fake "subpoenas" to pressure crime victims and witnesses to meet with them. The Fifth Circuit held that (1) at this early, motion to dismiss stage, the individual defendants are not entitled to absolute immunity for plaintiffs' subpoena-related state-law claims and (2) the court lacked jurisdiction to consider the merits of plaintiffs' claims. Accordingly, the court affirmed the district court's holding that the individual defendants are not entitled to absolute immunity for their alleged creation and use of fraudulent subpoenas, but dismissed the remainder of defendants' appeal for lack of jurisdiction. View "Singleton v. Cannizzaro" on Justia Law

On April 7, 2020, the Fifth Circuit issued a writ of mandamus vacating the district court's temporary restraining order (TRO) that exempted abortions from GA-09, an emergency measure temporarily postponing non-essential medical procedures during the COVID-19 pandemic. On April 9, 2020, the district court entered a second TRO exempting various categories of abortion from GA-09. At issue in this mandamus petition is the April 9 TRO.The court held that the district court disregarded the court's mandate in Abbott II and failed to apply the framework governing emergency exercises of state authority during a public health crisis, established over 100 years ago in Jacobson v. Commonwealth of Massachusetts, 197 U.S. 11 (1905). Furthermore, the district court second-guessed the basic mitigation strategy underlying GA-09 (the concept of "flattening the curve"), and also acted without knowing critical facts such as whether, during this pandemic, abortion providers do (or should) wear masks or other protective equipment when meeting with patients. The court concluded that these errors resulted in an overbroad TRO that exceeds the district court's jurisdiction, reaches patently erroneous results, and usurps the state's authority to craft emergency public health measures "during the escalating COVID-19 pandemic." Therefore, the court granted the writ in part and directed the district court to vacate parts of the April 9 TRO. View "In re: Greg Abbott" on Justia Law