Justia Constitutional Law Opinion Summaries

The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law

In this case, several plaintiffs challenged Hawaii and California laws that restrict the carrying of firearms in various locations, arguing that these laws violate their Second Amendment rights. The laws in question generally prohibit carrying firearms in places such as parks, beaches, bars, restaurants that serve alcohol, financial institutions, and private property without explicit consent from the property owner.The United States District Court for the District of Hawaii granted a preliminary injunction against Hawaii's law, enjoining the enforcement of the firearm restrictions in parking lots shared by government and non-government buildings, financial institutions, public beaches, public parks, bars, and restaurants that serve alcohol. The court also enjoined the new default rule for private property open to the public. The United States District Court for the Central District of California similarly granted a preliminary injunction against California's law, enjoining the enforcement of firearm restrictions in hospitals, playgrounds, public transit, parks, athletic facilities, places of worship, financial institutions, and private property open to the public.The United States Court of Appeals for the Ninth Circuit reviewed these decisions. The court affirmed the preliminary injunctions in part and reversed them in part. The Ninth Circuit held that some places specified by the Hawaii and California laws likely fall within the national tradition of prohibiting firearms at sensitive places, such as bars and restaurants that serve alcohol, parks, and similar areas. However, the court found that other places, such as financial institutions and places of worship, do not fall within this tradition. The court also held that the new default rule prohibiting the carry of firearms onto private property without consent is likely unconstitutional in California but not in Hawaii.The Ninth Circuit affirmed the preliminary injunctions to the extent that they enjoin restrictions on firearms at financial institutions, parking lots adjacent to financial institutions, and parking lots shared by government and non-government buildings. The court reversed the preliminary injunctions to the extent that they enjoin restrictions on firearms at bars and restaurants that serve alcohol, beaches, parks, and similar areas, and the new default rule prohibiting the carry of firearms onto private property without consent in Hawaii. View "WOLFORD V. LOPEZ" on Justia Law

Kekai Watanabe, an inmate at the Federal Detention Center in Honolulu, was severely injured during a gang-related assault in July 2021. Despite his serious injuries, including a fractured coccyx and bone chips in surrounding tissue, the prison nurse only provided over-the-counter medication and refused to send him to a hospital. Watanabe was kept in solitary confinement for over two months and repeatedly requested medical attention, which was largely ignored. He was not properly diagnosed until February 2022 and had not seen a specialist by the time of the court proceedings.The United States District Court for the District of Hawaii initially allowed Watanabe’s claim against the nurse to proceed but later dismissed it, concluding that no Bivens remedy existed for his Eighth Amendment claim. Watanabe appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The Ninth Circuit held that Watanabe’s claim did not present a new Bivens context, as it was not meaningfully different from the Supreme Court’s decision in Carlson v. Green, where an implied damages action was recognized under the Eighth Amendment for deliberate indifference to an inmate’s serious medical needs. The court found that Watanabe’s allegations were sufficiently similar to those in Carlson, thus allowing his Bivens claim to proceed.Additionally, the Ninth Circuit construed Watanabe’s request for injunctive relief related to his ongoing medical care as standalone claims for injunctive relief, not under Bivens. The court remanded the case to the district court to address whether Watanabe may amend his request for injunctive relief and to address any such claims in the first instance. View "WATANABE V. DERR" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

Plaintiffs, property developers owning three hotels, alleged that Defendants, rival developers operating the Hollywood Athletic Club, abused the California Environmental Quality Act (CEQA) processes to extort funds in violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). Defendants challenged several of Plaintiffs' hotel projects through CEQA objections and lawsuits, which Plaintiffs claimed were baseless and intended to obstruct their developments.The United States District Court for the Central District of California granted summary judgment in favor of Defendants, holding that the Noerr-Pennington doctrine protected Defendants' petitioning activities from statutory liability under the First Amendment. The district court found that Defendants' actions were not objectively baseless and thus did not fall within the sham litigation exception to the Noerr-Pennington doctrine. The case was transferred from Judge Wright to Judge Gutierrez, who reconsidered and reversed the prior denial of summary judgment, concluding that the previous decision was clearly erroneous and would result in manifest injustice.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The court held that the district court did not abuse its discretion in reconsidering the prior judge's ruling. It also agreed that Defendants' CEQA challenges were not objectively baseless, as the actions had some merit and were not brought solely for an improper purpose. The court emphasized that the Noerr-Pennington doctrine provides broad protection to petitioning activities to avoid chilling First Amendment rights. Consequently, the court did not need to address Defendants' additional arguments regarding the applicability of RICO to litigation activities. View "RELEVANT GROUP, LLC V. NOURMAND" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

The case involves X Corp., the owner of a large social media platform, challenging California Assembly Bill AB 587. This law requires large social media companies to post their terms of service and submit semiannual reports to the California Attorney General detailing their content-moderation policies and practices, including how they define and address categories like hate speech, extremism, and misinformation. X Corp. sought a preliminary injunction to prevent the enforcement of AB 587, arguing that it violates free speech and is federally preempted.The United States District Court for the Eastern District of California denied X Corp.'s motion for a preliminary injunction. The court found that X Corp. was unlikely to succeed on the merits of its First Amendment claim, applying the Zauderer standard for compelled commercial speech. The court concluded that the law's requirements were purely factual and uncontroversial, and reasonably related to the state's interest in transparency. The court also rejected X Corp.'s preemption argument, stating that AB 587 does not impose liability for content moderation activities but only for failing to make required disclosures.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The Ninth Circuit held that the Content Category Report provisions of AB 587 likely compel non-commercial speech and are subject to strict scrutiny because they are content-based. The court found that these provisions are not narrowly tailored to serve the state's interest in transparency and therefore likely fail strict scrutiny. The court also determined that the remaining factors for a preliminary injunction weighed in favor of X Corp. The Ninth Circuit remanded the case to the district court to enter a preliminary injunction consistent with its opinion and to determine whether the Content Category Report provisions are severable from the rest of AB 587. View "X CORP. V. BONTA" on Justia Law

Jesus Ramiro Gomez was sentenced to 188 months in prison for distributing methamphetamine. The district court applied a career offender enhancement, which significantly increased his sentence. This enhancement was based on Gomez's prior conviction for assault with a deadly weapon under California Penal Code § 245(a)(1), which the district court classified as a "crime of violence."The United States District Court for the Central District of California initially reviewed the case. The court found that Gomez's prior conviction qualified as a crime of violence, thus applying the career offender enhancement. This decision was based on previous rulings that had classified California Penal Code § 245(a)(1) as a crime of violence. Gomez did not object to this classification at the time of sentencing but raised the issue on appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court vacated Gomez's sentence and remanded for resentencing. The Ninth Circuit held that, in light of the Supreme Court's decision in Borden v. United States, 593 U.S. 420 (2021), California Penal Code § 245(a)(1) does not qualify as a crime of violence. The court reasoned that the statute includes reckless uses of force, which do not meet the elements clause of the career offender guideline requiring a mens rea more culpable than recklessness. The court also rejected the government's argument that the conviction could be classified as aggravated assault under the enumerated offenses clause, as this too requires a mens rea greater than extreme recklessness. Consequently, the district court's application of the career offender enhancement was deemed improper. View "USA V. GOMEZ" on Justia Law

In the summer of 2020, Derrick Sanderlin attended a protest in San Jose, California, where he was struck in the groin by a 40mm foam baton round fired by Officer Michael Panighetti. Sanderlin alleged that Panighetti's use of force was retaliatory and excessive, violating his First and Fourth Amendment rights. Sanderlin claimed he was peacefully protesting and did not hear any warnings before being shot. Panighetti argued that Sanderlin was obstructing officers from targeting other individuals who posed a threat.The United States District Court for the Northern District of California denied Panighetti's motion for summary judgment, concluding that genuine disputes of material fact existed regarding whether Panighetti's actions were retaliatory and whether the force used was excessive. The court found that a jury could determine that Sanderlin was engaged in protected First Amendment activity and that Panighetti's actions were motivated by retaliatory animus. Additionally, the court held that a reasonable jury could find that Sanderlin was seized under the Fourth Amendment and that the force used was unreasonable.The United States Court of Appeals for the Ninth Circuit affirmed the district court's denial of qualified immunity to Panighetti. The Ninth Circuit held that, viewing the evidence in the light most favorable to Sanderlin, genuine disputes of material fact existed as to whether Panighetti's use of force was retaliatory and excessive. The court concluded that it was clearly established that police officers may not use their authority to retaliate against individuals for protected speech and that the use of a 40mm foam baton round against a non-threatening individual constituted excessive force. The court also determined that subsequent legal developments did not alter the clearly established law at the time of the incident. View "SANDERLIN V. DWYER" on Justia Law

A group of plaintiffs, including Vicente Topasna Borja, challenged the federal Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA) and Hawaii’s Uniform Military and Overseas Voters Act (UMOVA). Borja, a former Hawaii resident now living in Guam, argued that these laws violate equal protection by allowing former Hawaii residents who move abroad or to the Commonwealth of the Northern Mariana Islands (CNMI) to vote absentee in Hawaii’s federal elections, while those who move to other U.S. Territories cannot.The United States District Court for the District of Hawaii found that the plaintiffs had standing to challenge the enforcement of UOCAVA but granted summary judgment in favor of the defendants. The court held that the plaintiffs did not have a fundamental right to vote in Hawaii’s federal elections and that those who move from a state to a territory are not a suspect or quasi-suspect class. Therefore, the court applied rational basis review and concluded that UOCAVA and UMOVA satisfied this standard.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that rational basis review, not strict scrutiny, applies to UOCAVA and UMOVA’s overseas voting provisions. The court reasoned that these laws do not deprive residents within a geographically defined governmental unit from voting in a unit-wide election nor dilute the voting power of qualified voters within Hawaii. The court found that the differential treatment of former Hawaii residents who move to other U.S. Territories versus those who move abroad or to the CNMI is rationally related to legitimate governmental interests. The court also rejected the argument that individuals who move from Hawaii to other U.S. Territories constitute a suspect or quasi-suspect class warranting heightened scrutiny.The Ninth Circuit concluded that UOCAVA and UMOVA’s classifications satisfy rational basis review and affirmed the district court’s judgment in favor of the defendants. View "BORJA V. NAGO" on Justia Law