Justia Constitutional Law Opinion Summaries

The Consumer Financial Protection Bureau (CFPB) brought an action against CashCall, Inc., alleging that CashCall engaged in unfair, deceptive, or abusive practices by attempting to collect interest and fees it was not legally entitled to. The CFPB sought legal restitution for the affected consumers. CashCall argued that the restitution order triggered its Seventh Amendment right to a jury trial.The United States District Court for the Central District of California initially granted partial summary judgment to the CFPB on liability and conducted a bench trial to determine the appropriate remedy. The court imposed a civil penalty but declined to order restitution. Both parties appealed, and the Ninth Circuit Court of Appeals affirmed the finding of liability but vacated the civil penalty and remanded for further proceedings regarding restitution.On remand, the district court ordered CashCall to pay over $134 million in legal restitution. CashCall appealed again, contending that the restitution order violated its Seventh Amendment right to a jury trial. The United States Court of Appeals for the Ninth Circuit assumed, without deciding, that CashCall had a right to a jury trial but concluded that CashCall had waived that right by voluntarily participating in the initial bench trial and not objecting to the second bench trial. The court also held that the district court did not abuse its discretion in concluding that the doctrines of judicial estoppel and waiver did not preclude the CFPB from seeking legal restitution. Additionally, the court found that the district court did not overstate CashCall’s unjust gains and properly used CashCall’s net revenues as a basis for measuring unjust gains. Finally, the court rejected CashCall’s argument that the CFPB’s funding mechanism violated the Appropriations Clause.The Ninth Circuit affirmed the district court’s judgment. View "CONSUMER FINANCIAL PROTECTION BUREAU V. CASHCALL, INC." on Justia Law

Andrew Grimm parked his car on a downtown street in Portland, Oregon, and paid for parking through a mobile app for a limited time. He left the car there for seven days, during which City parking enforcement officers issued multiple parking citations and placed them on the car’s windshield. After five days, an officer added a red slip warning that the car would be towed if not moved. Grimm did not move the car, and two days later, the car was towed.Grimm sued the City of Portland, claiming that the City’s procedures for notifying him of the impending tow were deficient under the Fourteenth Amendment’s Due Process Clause. The United States District Court for the District of Oregon granted summary judgment in favor of the City, holding that the City’s notice procedures were reasonable. The court found that although the accumulation of citations might have indicated that Grimm did not receive notice, no other form of notice was practicable.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit held that the City’s notice, which included a red warning slip placed on the car’s windshield two days before the tow, was reasonably calculated to inform Grimm of the impending tow, satisfying the requirements of the Fourteenth Amendment. The court further held that the City did not have actual knowledge that its attempt to provide notice had failed simply because the citations and warning slip remained undisturbed on the car’s windshield. Therefore, the City was not required to take additional steps to notify Grimm. The court affirmed the district court’s grant of summary judgment to the City. View "GRIMM V. CITY OF PORTLAND" on Justia Law

Shawn Sheltra, an inmate with the Idaho Department of Corrections (IDOC), filed a formal grievance in March, identifying safety concerns and threats from other inmates in his housing unit. He warned that he would be attacked in April if he did not make an extortion payment. Despite being briefly isolated, Sheltra was returned to his housing unit and was attacked by another inmate in April. He subsequently filed a lawsuit, asserting violations of the Eighth and Fourteenth Amendments due to the defendants' failure to protect him from a known harm.The United States District Court for the District of Idaho granted summary judgment for the defendants, dismissing the action for failure to exhaust administrative remedies because Sheltra did not file a formal grievance after the April attack. The court also granted summary judgment for the defendants on Sheltra's official-capacity claims, as they were barred by the Eleventh Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and adopted the continuing-violations doctrine for purposes of administrative exhaustion under the Prison Litigation Reform Act (PLRA). The court held that a properly exhausted prison grievance asserting one continuing harm or a single course of conduct can exhaust events arising out of the same alleged violation that occur after the grievance was made. Applying this doctrine, the court concluded that Sheltra's attack was part of the same continuing harm or course of conduct described in his prison grievance before the attack. Therefore, the court reversed the district court's summary judgment on Sheltra's individual-capacity claims against the defendants. However, the court affirmed the district court's grant of summary judgment for the defendants on Sheltra's official-capacity claims due to Eleventh Amendment immunity. View "SHELTRA V. CHRISTENSEN" on Justia Law

Yaakov Markel, an Orthodox Jewish man, worked as a mashgiach for the Union of Orthodox Jewish Congregations of America (OU) from 2011 to 2018. His role involved supervising food preparation to ensure kosher compliance, particularly for grape products. Markel claimed that his supervisor, Rabbi Nachum Rabinowitz, promised him a promotion and a raise, which he did not receive, and that OU withheld certain overtime compensation. Markel resigned and filed suit, bringing wage and hour and fraud and misrepresentation claims against OU and Rabbi Rabinowitz.The United States District Court for the Central District of California granted summary judgment in favor of the defendants, holding that the First Amendment’s ministerial exception barred Markel’s employment-related claims. The court determined that OU is a religious organization and that a mashgiach is considered a minister within Orthodox Judaism, thus invoking the ministerial exception.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the ministerial exception categorically barred Markel’s claims because OU is a religious organization and a mashgiach is a minister. The court emphasized that the acceptance of revenue does not deprive an organization with a religious mission of First Amendment protections. The court also rejected Markel’s argument that the ministerial exception was inapplicable because his dispute involved only secular issues, noting that a religious institution’s decisions, even if facially secular, are often intertwined with religious doctrine. The court further held that the ministerial exception protects both religious organizations and their leaders from claims brought by ministerial employees. View "MARKEL V. UNION OF ORTHODOX JEWISH CONGREGATIONS OF AMERICA" on Justia Law

Michael Blake DeFrance was convicted of assaulting his girlfriend in 2013 under Montana Code Annotated section 45-5-206(1)(a), a misdemeanor. In 2018, he was found in possession of three firearms, leading to a federal indictment for violating 18 U.S.C. § 922(g)(9), which prohibits firearm possession by individuals convicted of a misdemeanor crime of domestic violence.The United States District Court for the District of Montana denied DeFrance's motion to dismiss the indictment, which argued that the Montana statute could be violated without the use of physical force. DeFrance was subsequently convicted and appealed the decision.The United States Court of Appeals for the Ninth Circuit reviewed the case and applied the categorical approach to determine whether a conviction under Montana's PFMA statute qualifies as a "misdemeanor crime of domestic violence" under 18 U.S.C. § 922(g)(9). The court concluded that because the Montana statute can be violated by inflicting emotional distress rather than physical injury, it does not have, as an element, the use or attempted use of physical force as required by 18 U.S.C. § 921(a)(33)(A)(ii). Consequently, the court held that DeFrance's conviction under the Montana statute does not qualify as a misdemeanor crime of domestic violence.The Ninth Circuit reversed DeFrance's conviction under 18 U.S.C. § 922(g)(9), vacated his sentence, and remanded the case for resentencing or other proceedings consistent with their opinion. View "USA V. DEFRANCE" on Justia Law

Residents of Humboldt County filed a putative class action under 42 U.S.C. § 1983, alleging that the County’s system of administrative penalties and fees for cannabis abatement violates the Eighth Amendment’s Excessive Fines Clause. The County Code imposes daily fines of $6,000 to $10,000 for illegal cannabis cultivation. Plaintiffs claimed that the County charges landowners based on imprecise data or previous owners' conduct, causing emotional distress and financial burdens due to ongoing penalties and abatement costs.The United States District Court for the Northern District of California dismissed the case, concluding that plaintiffs lacked standing as they had not paid any fines, rendering the Eighth Amendment claim unripe. The court also found both facial and as-applied challenges untimely, reasoning that the statute of limitations began when the ordinance was enacted.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that plaintiffs’ claim under the Excessive Fines Clause was constitutionally ripe and that they had standing due to the imposition of penalties causing concrete injuries, including emotional distress and financial expenses. The court also found that prudential ripeness considerations supported allowing the litigation to proceed. The court determined that the statute of limitations for facial challenges begins when plaintiffs know of the actual injury, not when the ordinance is enacted. Thus, some plaintiffs’ facial challenges were timely. The court also found that several plaintiffs had timely as-applied challenges, except for Cyro Glad, whose claim was untimely.On the merits, the Ninth Circuit held that plaintiffs plausibly alleged a violation of the Excessive Fines Clause, as the penalties and demolition orders were punitive and potentially excessive. The court reversed the district court’s dismissal of the Eighth Amendment claim and remanded for further proceedings, affirming the dismissal only for Cyro Glad’s as-applied claim. View "THOMAS V. COUNTY OF HUMBOLDT" on Justia Law

A nonprofit corporation, Moving Oxnard Forward (MOF), challenged campaign finance limitations in the Oxnard City Code, alleging they violated the First Amendment. The limitations, adopted by the City of Oxnard, California, primarily affected Aaron Starr, MOF's President, who had a history of receiving large contributions and challenging the City Council's policies. Starr had previously led recall efforts against the City Council and ran for Mayor, relying on larger-dollar contributions.The United States District Court for the Central District of California granted summary judgment in favor of the City, upholding the campaign finance limitations. MOF appealed the decision, arguing that the limitations were designed to target and suppress Starr's political activities rather than to prevent corruption.The United States Court of Appeals for the Ninth Circuit reviewed the case and found significant "danger signs" of invidious discrimination against Starr. The court noted that the legislative record and the practical impact of the limitations disproportionately affected Starr, who had been a vocal critic of the City Council. The court also found that the City's justification for the limitations, based on a 2010 corruption scandal, was tenuous and unrelated to campaign contributions.The Ninth Circuit concluded that the contribution limits were not narrowly tailored to the City's interest in preventing quid pro quo corruption. Instead, the limits appeared to be more closely drawn to suppress Starr's political activities. As a result, the court reversed the district court's decision and remanded with instructions to grant summary judgment in favor of MOF, holding that the per-candidate aggregate contribution limitations in the Oxnard City Code violated the First Amendment. View "MOVING OXNARD FORWARD, INC. V. ASCENSION" on Justia Law

In this case, two organizations and four individuals brought an action under 42 U.S.C. § 1983 against the City of Phoenix and several police officers, alleging violations of their constitutional rights during a protest outside a rally held by then-President Trump at the Phoenix Convention Center on August 22, 2017. The plaintiffs claimed that the police used excessive force and violated their First, Fourth, and Fourteenth Amendment rights by dispersing the protesters with tear gas, chemical irritants, and flash-bang grenades.The United States District Court for the District of Arizona certified two classes and granted summary judgment to the defendants on all claims except for the individual Fourth Amendment excessive-force claims asserted by three plaintiffs against certain officers. The court found that there was no "seizure" of the class members under the Fourth Amendment and evaluated the excessive-force claims under the Fourteenth Amendment's "shocks-the-conscience" test. The court also granted summary judgment to the defendants on the First Amendment claims, finding no evidence of retaliatory intent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's summary judgment for the defendants on the class claims. The Ninth Circuit agreed that the use of airborne and auditory irritants did not constitute a "seizure" under the Fourth Amendment and that the Fourteenth Amendment's "purpose to harm" standard applied. The court found no evidence of an improper purpose to harm by the officers.The Ninth Circuit reversed the district court's denial of summary judgment to the individual defendants on the excessive-force claims asserted by the three plaintiffs, holding that the officers were entitled to qualified immunity. The court found that the officers acted reasonably under the circumstances or did not violate clearly established law. The court also affirmed the district court's summary judgment for the individual defendants on the First Amendment claims, finding that the officers had objectively reasonable grounds to disperse the crowd due to a clear and present danger.Finally, the Ninth Circuit affirmed the district court's summary judgment for Police Chief Williams and the City of Phoenix, concluding that there was no evidence that Williams caused or ratified the use of excessive force or that the City was deliberately indifferent to the plaintiffs' constitutional rights. View "PUENTE V. CITY OF PHOENIX" on Justia Law

Maverick Gaming LLC, a casino gaming company, filed a lawsuit challenging the State of Washington's tribal-state compacts that allow sports betting on tribal land. Maverick argued that these compacts violate the Indian Regulatory Gaming Act (IGRA), the Equal Protection Clause, and the Tenth Amendment. Maverick sought to invalidate the gaming compacts and amendments that permit sports betting on tribal lands, which would allow them to offer similar gaming activities at their cardrooms.The United States District Court for the Western District of Washington dismissed Maverick's lawsuit. The court found that the Shoalwater Bay Indian Tribe, which intervened for the limited purpose of filing a motion to dismiss, was a required party under Federal Rule of Civil Procedure 19(a). The court determined that the Tribe had a legally protected interest in the lawsuit that could be impaired or impeded in its absence. The court also concluded that the Tribe could not be feasibly joined in the litigation due to its sovereign immunity. Consequently, the court ruled that the litigation could not proceed in equity and good conscience without the Tribe and dismissed the case.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The Ninth Circuit agreed that the Tribe was a required party with a substantial interest in the legality of its gaming compact and sports betting amendment. The court also found that the federal government could not adequately represent the Tribe's interests, as their interests diverged in meaningful ways. The court held that the Tribe's sovereign immunity prevented its joinder, and the litigation could not proceed without the Tribe. The court rejected Maverick's argument that the public rights exception should apply, as the suit threatened the Tribe's legal entitlements and sovereignty. View "Maverick Gaming LLC V. United States" on Justia Law

Lloyd Gerald Napouk was fatally shot by two Las Vegas Metropolitan Police Department officers after they responded to reports of a man behaving suspiciously in a residential neighborhood with what appeared to be a long, bladed weapon. The officers attempted to engage Napouk, who refused to follow their commands and advanced towards them multiple times. When Napouk came within nine feet of one of the officers, both officers fired their weapons, killing him. The weapon turned out to be a plastic toy fashioned to look like a blade.Napouk’s parents and estate sued the officers and the Las Vegas Metropolitan Police Department, alleging excessive force in violation of the Fourth Amendment, deprivation of familial relations in violation of the Fourteenth Amendment, municipal liability based on Monell v. Department of Social Services, and Nevada state law claims. The United States District Court for the District of Nevada granted summary judgment for the defendants, determining that the officers’ use of force was reasonable as a matter of law.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court held that the officers were entitled to qualified immunity from the Fourth Amendment excessive force claim because Napouk posed an immediate threat to the officers, and no rational jury could find the officers’ mistake of fact regarding the weapon unreasonable. The court also held that the plaintiffs’ Fourteenth Amendment claim failed because there was no evidence that the officers acted with anything other than legitimate law enforcement objectives. Additionally, the plaintiffs’ Monell claims failed due to the absence of a constitutional violation, and the state law claims failed because the officers were entitled to discretionary-function immunity under Nevada law. View "Napouk v. Las Vegas Metropolitan Police Department" on Justia Law