Justia Constitutional Law Opinion Summaries

Plaintiff’s father died of carbon monoxide poisoning in his apartment at Allen Benedict Court Apartments, a housing complex owned and maintained by the City of Columbia Housing Authority. The city police and fire chiefs concluded that the cause of the man’s death was a faulty, thirty-year-old furnace that had caused carbon monoxide to leak into his apartment, as well as several others. Plaintiff and the personal representative of his estate appealed the district court’s dismissal of her complaint against the City of Columbia Housing Authority (“Housing Authority”) for failure to state a claim upon which relief could be granted.   The Fourth Circuit reversed, concluding that Plaintiff alleged sufficient facts to plead a Section 1983 claim against the Housing Authority. The court wrote that Plaintiff has alleged enough facts at this early stage to establish that the Housing Authority recognized the risk of carbon monoxide poisoning and acted inappropriately in light of that risk. By affirmatively adopting regulations recognizing the life-threatening danger of missing carbon monoxide detectors, the Housing Authority demonstrated that it knew the risk of harm that the man faced. Specifically, the Housing Authority failed to install a single carbon monoxide detector at the man’s 244-unit complex. It provided no preventative maintenance of appliances. In sum, at this early stage, Plaintiff has alleged sufficient facts to establish that the Housing Authority’s policies and customs were the moving force behind the constitutional injury. View "Danielle Washington v. Housing Authority of the City of Columbia" on Justia Law

Plaintiff spent nearly three months in Middle River Regional Jail. And he alleges that Middle River’s practices during that time substantially burdened his Islamic faith while unconstitutionally favoring the practice of Christianity. He argues that he was kept from engaging in Friday Prayer.   Plaintiff’s claims regarding Friday Prayer implicate the Free Exercise Clause. Under that clause, prisons can impose burdens on inmates’ religious practice— even substantial burdens—so long as the prison rules that do so are “reasonably related to legitimate penological interests.” Middle River had three rules in place that kept Plaintiff from attending in-person Friday Prayer: no inmate led groups; no maximum-security prisoners allowed in any in-person groups; and prisoner services and classes by volunteer or donation only.   The Fourth Circuit affirmed the district court’s Free Exercise decision and remanded for further proceedings on the Establishment Clause. The court explained that Middle River’s policies do not violate the Free Exercise Clause. Each of the rules and regulations that combined to keep Plaintiff from engaging in communal Friday Prayer during his brief stay was reasonably related to a legitimate penological interest and, therefore, acceptable under Turner. Whether the challenged practices violate the Establishment Clause is a question best left to the district court to resolve in the first instance, with the benefit of intervening legal developments. View "David Firewalker-Fields v. Jack Lee" on Justia Law

Appellee a middle school teacher in Pender County, North Carolina, when she was physically attacked by a special education student in her language arts class. There is no dispute that the student was known to have been violent on prior occasions. At the time of the incident involving Appellee, Appellant was the principal of the school where the attack occurred.   Appellee asserted the following five 42 U.S.C. Section 1983 claims: (1) a substantive due process claim; (2) a deliberate indifference claim; (3) a supervisory liability claim against Superintendent Hill; (4) a claim seeking personal liability against Superintendent Hill; and (5) a claim seeking personal liability against Appellant. Relevant here, the personal liability claim against Appellant alleges that Appellant knew or should have known that her actions and inactions could have led to a violation of Appellee’s constitutional rights.   The Fourth Circuit reversed and remanded. The court held that Appellee failed to sufficiently allege that Appellant violated her constitutional rights, thus Appellant is entitled to qualified immunity. The court explained that here, Appellee’s state-created danger claim centers on a series of alleged choices or inactions by Appellant which are far removed from TB’s physical attack on Appellee. Specifically, Appellee attempts to recast Appellant’s knowledge of TB’s prior acts of violence and creation of the staffing schedule which required Appellant to teach TB on the day of the incident -- without a second teacher in her classroom -- as affirmative acts. But Appellee fails to point to any action by Appellant which created the danger that resulted in Appellee’s injuries. View "Kimberly Burns-Fisher v. Anna Romero-Lehrer" on Justia Law

A bankruptcy court imposed sanctions against Defendant. The sanctions arose from an adversary proceeding in the bankruptcy court brought by the United States Trustee against Defendant, UpRight Law LLC, Sperro LLC and other defendants. UpRight is a Chicago-based bankruptcy legal services company that operates through a nationwide network of “local partners.” After Defendant signed a partnership agreement with UpRight, he filed more than 30 bankruptcy cases as a partner. The bankruptcy court also found that Delafield violated Virginia Rules of Professional Conduct 5.1 and 5.3. After the district court affirmed sanctions, Defendant appealed, asserting the sanctions order violated his due process rights.   The court explained that to be sure, a lawyer facing suspension or disbarment is entitled to notice of the charges for which such discipline is sought and an opportunity to be heard on those issues. The court explained that the complaint did not cite to the Virginia Rules of Professional Conduct that Defendant was ultimately found to have violated. Identifying such rules is certainly preferred in an action seeking suspension or disbarment. But this omission did not violate Defendant’s due process rights. The complaint adequately notified Defendant of the conduct for which he was being accused and the sanctions that were being sought. View "U. S. Trustee v. Darren Delafield" on Justia Law

Defendant and another person were trespassing in a public park after it closed. When officers saw their car, they investigated the trespass. The officers found a gun abandoned in a nearby trash can, so they frisked Defendant and questioned him about the gun. After first denying the gun was his, Defendant admitted he was a felon and that he owned the gun. The officers arrested Defendant, who was then federally indicted for being a felon in possession of a firearm. He sought to suppress his incriminatory statements, arguing that his statements in the park were inadmissible because he was “in custody” under Miranda, and so the officers needed to read him his Miranda rights before questioning him about the gun. The district court disagreed, and Defendant pleaded guilty.   The Fourth Circuit affirmed. The court explained that Miranda warnings are not required every time an individual has their freedom of movement restrained by a police officer. Nor are they necessarily required every time “questioning imposes some sort of pressure on suspects to confess to their crimes.” Instead, they are required only when a suspect’s freedom of movement is restrained to the point where they do not feel free to terminate the encounter, and the circumstances reveal “the same inherently coercive pressures as the type of station house questioning at issue in Miranda.” The court found that, in this case, no such pressures existed. View "US v. Ervin Leggette" on Justia Law

A real estate development company PEM Entities LLC (PEM), asserts a North Carolina county violated the Federal Constitution and state law by imposing new rules for getting water and sewage services. The district court dismissed the complaint, concluding the company lacked standing to bring its takings and due process claims, its equal protection claim was too insubstantial to raise a federal question, and the court should not exercise jurisdiction over the state law claims once the federal claims were dismissed.   The Fourth Circuit affirmed. The court explained that without a constitutionally protected property interest, PEM’s takings and due process claims fail as a matter of law. Accordingly, the court affirmed the district court’s dismissal of PEM’s takings and due process claims because they fail to state a claim on which relief can be granted. Further, the court concluded the district court was right to dismiss PEM’s equal protection claim but should have done so for failure to state a claim rather than lack of jurisdiction. Thu, having concluded the district court correctly dismissed all of PEM’s federal claims, the court saw no abuse of discretion in the district court’s decision not to exercise supplemental jurisdiction over the state law claims. View "PEM Entities LLC v. County of Franklin" on Justia Law

Plaintiffs brought suit against Weinstein Management Co., Inc., and WMCI Charlotte XIII, LLC (collectively, Defendants). In relevant part, Plaintiffs alleged that Defendants violated the North Carolina Residential Rental Agreements Act (RRAA), and the North Carolina Debt Collection Act (NCDCA), by charging them out-of-pocket costs for summary ejectment proceedings, including filing fees, service fees, and attorney’s fees (collectively, out-of-pocket expenses). The district court granted Defendants’ motion for judgment on the pleadings on these claims, and Plaintiffs appealed. At issue on appeal is whether he 2021 amendment applies retroactively without violating vested rights, thereby extinguishing Plaintiffs’ RRAA and NCDCA claims.   The Fourth Circuit affirmed. The court explained that here, the 2021 amendment’s text provides that it “is effective when it becomes law and is intended to apply retroactively to all pending controversies as of that date.” The court wrote that given this explicit language from the General Assembly, the intent of the legislature to apply the 2021 amendment retroactively could not be clearer. The North Carolina Supreme Court has repeatedly held that the General Assembly cannot retroactively invalidate common-law rights, which Plaintiffs do not seek to vindicate here. Therefore, the district court was not precluded from applying the 2021 amendment retroactively. View "Tiffany Bass v. Weinstein Management Co., Inc." on Justia Law

Appellee filed suit against two Transportation and Security Administration (“TSA”) officers, (collectively “Appellants”), alleging they violated the First Amendment by prohibiting Appellee from recording a pat-down search and the Fourth Amendment by seizing Appellee and seizing and searching his cell phone. To state a cause of action for damages, Appellee brought his claims pursuant to Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971). Appellants moved to dismiss, challenging Appellee’s reliance on Bivens and also asserting qualified immunity as to Appellee’s First Amendment claim. The district court denied Appellants’ motion, recognizing that both claims presented new Bivens contexts but finding that no special factor counseled hesitation in extending Bivens as to either claim.   The Fourth Circuit disagreed with the district court and concluded that Bivens remedies are unavailable in this case. The court explained that as “even a single sound reason to defer to Congress” will be enough to require the court refrain from creating a Bivens remedy, we decline to extend an implied damages remedy pursuant to Bivens against Appellants based on the existence of an alternative remedial structure and/or the interest of national security. And since Appellee has presented no cognizable claim for damages, we need not address Appellants’ qualified immunity defense as to Appellee’s First Amendment claim. Therefore, the court reversed the district court’s denial of Appellants’ motion to dismiss and remanded with instructions to dismiss. View "Dustin Dyer v. Shirrellia Smith" on Justia Law

Section 20.5 of North Carolina’s 2017 Farm Act contains provisions making it illegal to enter into two types of contractual agreements: (1) any settlement agreement conditioned on an agricultural producer’s union affiliation (the Settlement Provision) and (2) any agreement that would require an agricultural producer to process dues checkoffs for its farmworker-employees (the Dues Provision). The Farm Labor Organizing Committee and others (collectively, FLOC) contend that these prohibitions violate the First Amendment, Fourteenth Amendment, and 42 U.S.C. Section 1981. FLOC initiated this action against the Attorney General of North Carolina and the Governor of North Carolina (collectively, the State). The district court held that the Settlement Provision violated the Constitution and so enjoined it, but upheld the constitutionality of the Dues Provision, and then held that neither provision violated Section 1981.   The Fourth Circuit reversed the judgment of the district court as to the Settlement Provision and vacated the accompanying injunction, but affirmed in all other respects. The court explained that a rational basis supports Section 20.5. Agriculture is North Carolina’s largest industry, which makes it a subject of great interest for state legislators. The state also embraces its right-to-work policies and has worked repeatedly to strengthen them. In addition to these general bases for enacting Section 20.5, both challenged provisions respond to discrete legislative concerns. Further, the Settlement Provision prohibits parties from conditioning a settlement agreement on an agricultural producer’s union affiliation. Thus, the court rejected the broad reading advanced by FLOC and adopted by the district court that this statutory provision bars any settlement agreement between an agricultural producer and labor union. View "Farm Labor Organizing Committee v. Joshua Stein" on Justia Law

Plaintiff’s estate sued the Virginia Department of Corrections (“Department”) and several prison officials under 42 U.S.C. Section 1983 and Virginia law, alleging that they violated the Eighth Amendment and state law by failing to provide Plaintiff treatment for his chronic hepatitis C until it was too late.   Defendants in this appeal are Dr. A and Dr. W. Plaintiff alleges that Dr. A designed treatment guidelines for inmates with hepatitis C that unconstitutionally excluded Plaintiff from receiving treatment. Plaintiff also alleges that Dr. W failed to follow those guidelines and committed both medical malpractice and Eighth Amendment violations in denying him appropriate treatment. Defendants unsuccessfully moved for summary judgment, alleging that they were protected by qualified immunity and, on Dr. W’s part, derivative sovereign immunity.   The Eighth Circuit reversed the district court’s denial of sovereign immunity to Dr. W and denial of qualified immunity to Dr. A but affirm its denial of qualified immunity to Dr. W. The court declined to hold that Dr. A was clearly on notice that he should have ordered the Department’s primary care providers to prescribe this novel treatment rather than referring patients to specialists for treatment.  Further, the court explained a prisoner’s purported right not to be subjected to a treatment regimen that prioritized antiviral treatment to prisoners with the most advanced levels of fibrosis was not clearly established when Dr. A designed the Guidelines in 2015. Moreover, three of the four factors strongly weigh in favor of sovereign immunity, and one only moderately weighs against it. Therefore, the court concluded that the district court erred by rejecting Dr. W’s sovereign-immunity defense. View "Jacob Pfaller v. Mark Amonette" on Justia Law