Justia Constitutional Law Opinion Summaries

Adams, his girlfriend, Brandon, and another person were stopped for speeding. Adams was the subject of anonymous tips regarding drug activity at his house and had a previous conviction for conspiracy to distribute methamphetamine. The third person was also the subject of anonymous tips regarding drug activity and had outstanding arrest warrants. During the traffic stop, the deputy smelled marijuana from the car. The car was searched, and deputies found a meth pipe, paraphernalia used with marijuana, and marijuana. Brandon, after receiving Miranda warnings, told the deputy that additional drug paraphernalia, a gun, and a safe containing methamphetamine pipes were at Adams’ house; that she also stayed in the house; and that she had been there earlier that day. She described the house’s layout, Adams’ bedroom, the gun, and paraphernalia. The police obtained a state-court search warrant, which they executed the same day as the traffic stop. In Adams’ room, they found a locked plastic gun case that Brandon had described, a handgun, and loaded magazines. Adams later admitted that Brandon bought the gun for him. Charged with unlawful possession of a firearm by a felon, 18 U.S.C. 922(g), Adams unsuccessfully moved to suppress the evidence. The Seventh Circuit affirmed. The issuing judge had a “substantial basis for determining the existence of probable cause” and, if “it didn’t ... there is good faith.” The district court properly calculated Adams’ guideline range, taking into account his prior drug conspiracy conviction. View "United States v. Adams" on Justia Law

In 2007, Campbell pleaded guilty to first-degree sexual assault of a child and was sentenced to 34 years in prison. Campbell has gender dysphoria; she is biologically male but identifies as female. Department of Corrections (DOC) medical staff treat Campbell’s condition with hormone therapy. Beginning in 2013, Campbell repeatedly requested sex-reassignment surgery. National standards of care recommend that patients undertake one year of “real life” experience as a person of their self-identified gender before resorting to irreversible surgery, which presents challenges in sex-segregated prisons. DOC officials consulted an outside expert, who determined that Campbell was a potential surgical candidate if DOC officials developed a safe, workable solution to the real-life-experience dilemma. Citing these concerns and DOC policy, officials denied Campbell’s request. After exhausting administrative remedies, Campbell sued under 42 U.S.C. 1983, alleging deliberate indifference to her serious medical needs.The Seventh Circuit reversed the denial of defendants’ claim of qualified immunity. Qualified immunity shields public officials from suits for damages unless precedent clearly puts them on notice that an action is unconstitutional. The Eighth Amendment requires prison healthcare professionals to exercise medical judgment when making decisions about an inmate’s treatment; they cannot completely deny care for a serious medical condition. Those broad principles could not have warned these defendants that treating an inmate’s gender dysphoria with hormone therapy and deferring consideration of sex-reassignment surgery violates the Constitution. The defendants followed accepted medical standards and are immune from damages liability. View "Campbell v. Kallas" on Justia Law

Landlords challenged a Hammond ordinance that they either obtain a city license or hire licensed contractors to perform repairs and renovations to their properties. Obtaining a license involves a test, payment of a fee, and a criminal background check. The ordinance does not apply to individual homeowners working on the properties in which they reside. On summary judgment, the district court rejected their argument that the ordinance impermissibly burdens owners who do not reside in Hammond. The Seventh Circuit affirmed. The ordinance does not discriminate against non-residents and is supported by a rational basis. The court noted the significant differences between resident owners and landlords and the city’s interests in safety and the habitability of dwellings. View "Regan v. City of Hammond" on Justia Law

Clark was convicted under 21 U.S.C. 841(a)(1), having been found in a hotel room with more than 80 grams of a mixture of heroin and fentanyl, a digital scale, and cellophane bags. He appealed the denial of his motion for a Franks hearing challenging the search warrant; the denial of his motion to suppress without an evidentiary hearing; the guideline treatment of his conviction for drug distribution that occurred in Illinois seven months after his Wisconsin arrest and one condition of supervised release.The Seventh Circuit vacated Clark’s conviction and remanded for an evidentiary hearing on his Franks challenge. Merely to obtain a Franks hearing, a defendant need only make a substantial preliminary showing that the warrant application contained a material falsity or omission that would alter the issuing judge’s probable cause determination and that the affiant included the material falsity or omitted information intentionally or with a reckless disregard for the truth. Clark asserted that the police investigator who applied for the warrant deliberately or recklessly omitted critical information affecting the credibility of the unidentified informant who told police about drug distribution at the hotel. Here, the foundation for probable cause independent of the credibility of the informant was so meager that the informant's credibility was material for Franks purposes. The police had provided no information about the informant’s credibility. The court rejected Clark's other claims. View "United States v. Clark" on Justia Law

While Giles was in solitary confinement following state robbery convictions, FBI agents questioned Giles about another bank robbery. DNA recovered from a glove found next to dye-stained stolen money matched Giles’s DNA. Giles agreed in writing to be questioned without an attorney present. After he was shown the DNA report, Giles confessed to the robbery and agreed to a cheek swab after being advised of his right to refuse. Giles was indicted for bank robbery, 18 U.S.C. 2113, and using a firearm in relation to a crime of violence 18 U.S.C. 924(c). He unsuccessfully moved to suppress the confession, arguing that neither his Miranda waiver nor his confession were voluntary, given his long-term confinement in a “small windowless cell” with little opportunity for human interaction. A psychiatrist who had conducted a forensic psychiatric evaluation and reviewed medical records testified that prolonged isolation could result in impaired function and that Giles's history of psychological disorders and head trauma made him particularly vulnerable to the effects of isolation. A fellow inmate testified that he spoke to Giles regularly. Bacha testified that Giles showed no signs of mental distress. The Seventh Circuit affirmed and upheld his sentence, which effectively added 18 years to the term he was serving, reasoning that there was enough evidence to convict Giles without the confession. His conduct and statements reflected a clear, intelligent, and knowledgeable thought process. View "United States v. Giles" on Justia Law

The Prison Litigation Reform Act (PLRA) “three strikes” provision, 28 U.S.C. 1915(g), specifies that a prisoner may not proceed in forma pauperis if she “has, on [three] or more prior occasions, while incarcerated or detained in any facility, brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted.” Many courts require prisoner‐litigants to identify their entire litigation histories. The Northern District of Illinois’s form requires 42 U.S.C. 1983 inmate-plaintiffs to list the name of each case, assigned judge and court, docket number, filing date, all plaintiffs (with aliases), all defendants, a description of claims made, the disposition and date of disposition. In cases consolidated on appeal, the district court concluded that inmate-plaintiffs committed fraud. The Seventh Circuit vacated. District courts must ensure that a prisoner’s negligent or even reckless mistake is not improperly characterized as an intentional and fraudulent act. Even prisoners with no incentive to lie may not have ready access to their litigation documents and may not remember all of the details. When viewed in the liberal light appropriate for pro se pleadings, one inmate’s explanation of his mental health issues and illiteracy indicated he did not fully understand what was being asked of him; the omissions were inadvertent. None of the cases omitted by the inmates met applicable standards for materiality. View "Johnson v. Dalke" on Justia Law

Paul Koh, 22, was found in a pool of blood next to a knife in his home, having been stabbed in the throat and chest. Officers initially noted a possibility of suicide. Paul's parents' requests to see Paul, get medicine and cell phone, and to go to the hospital were denied. They were taken to the police department and not allowed to make calls. Officer Kim, who spoke Korean socially, served as a translator but did not translate everything. Mr. Koh was questioned for 150 minutes. Koh claims Officer Graf “told me that the only person I could see was a lawyer... I didn’t have any phone numbers, so that was the end” and that Kim advised that he did not need an attorney. His Miranda warnings were in English. Some of Koh's responses were confusing or nonresponsive. Koh denied any involvement in Paul’s death. There was evidence suggesting a struggle and of tension in the family. During a second interview, officers pressed harder, stating, “We can be here for days” and asking questions at a rapid pace, with mistranslations. Koh gave short responses that could be interpreted as agreeing with Graf’s self-defense theory.Koh, acquitted on state murder charges after four years in the Cook County Jail, sued under 42 U.S.C. 1983. The district court denied the defendants summary judgment on false arrest claims, but held that Koh’s false arrest ended when the officers later had probable cause to arrest him; denied summary judgment on Koh’s coerced confession, conspiracy and failure to intervene, and municipal liability false arrest claims. The court granted the defendants summary judgment on Koh’s malicious prosecution, substantive due process, evidence-fabrication. and pretrial detention (Fourth Amendment) claims. The Seventh Circuit dismissed appeals on the issue of qualified immunity concerning coerced confession as inseparable from the questions of fact identified by the district court. View "Koh v. Ustich" on Justia Law

Pretrial detainees at the Lake County Adult Correctional Facility allege that for approximately three days, jail officials shut off all water in their jail without any warning. The shutdown was apparently conducted in order to replace a pump. With no running water, the detainees were provided with five bottles of water for their personal and sanitation uses and with a communal barrel of water for each pod in the jail. As a result, they became ill and feces built up and festered in the jails’ toilets, attracting insects. When plaintiffs asked for more water, they were locked down in their cells as punishment. The detainees filed a putative class action, alleging violations of their Fourteenth Amendment due process rights. The district court denied the defendants’ motion for summary judgment on the basis of qualified immunity. The Seventh Circuit affirmed. The rights that plaintiffs identify—to have enough water for drinking and sanitation, and not to be forced to live surrounded by their own and others’ excrement—are clearly established. Regardless of the legitimacy of the jail’s objective, taking as true the conditions described in the complaint, with plausible inferences, the conditions of confinement were objectively unreasonable and “excessive in relation to” any legitimate non-punitive purpose. View "Hardeman v. Wathen" on Justia Law

Chicago Officers stopped Martin for non-functioning tail and brake lights. Martin claims he had not committed any traffic violations. Martin explained that he did not have his driver’s license. The officers asked Martin to step out of the car as additional officers arrived. Martin claims the officers forced him from the car, conducted a pat-down search, handcuffed him, put him into a police car, then searched his car, where they recovered a semiautomatic handgun with a defaced serial number and a baggie of crack cocaine. Martin had previously been convicted of first-degree murder and unlawful use of a weapon by a convicted felon. Martin was charged with various crimes under Illinois law and spent 65 days incarcerated. The state court granted Martin’s motion to suppress the evidence. The charges were dismissed. Martin filed suit under 42 U.S.C. 1983. The officers argued that even if the stop was unlawful, once officers saw the handgun and cocaine, they had probable cause for Martin’s arrest, which limited Martin’s damages to the period between his stop and his arrest. The district court agreed. The jury awarded him $1.00. The Seventh Circuit affirmed. The jury concluded that the officers unlawfully seized Martin without reasonable suspicion, but found against Martin on the claim that officers either arrested him or searched him or his car without probable cause. The only Fourth Amendment injury being redressed is the brief initial seizure before officers asked for Martin's license. View "Martin v. Marinez" on Justia Law

Lavite, a combat veteran, works in the Administration Building of Madison County, Illinois, as superintendent for the County’s Veterans Assistance Commission. In 2015, Madison County officials banned Lavite from the Administration Building indefinitely after learning that Lavite had experienced a PTSD episode during which he threatened a police officer and then kicked out the windows of a squad car. The ban lasted for nearly 20 months. Lavite kept his job but had to work remotely. Lavite had previously resisted efforts to use funds from the Commission’s budget for other county needs. Before the ban was lifted, Lavite filed suit. The district court granted summary judgment for the defendants. The Seventh Circuit affirmed. Lavite’s right to assemble on government property was not violated because the ban on his presence in the building was viewpoint-neutral and reasonably motivated by legitimate safety concerns. None of the evidence supports a reasonable inference of causation between the ban imposed on Lavite in 2015 and his 2013 objections to the proposals to divert some of his Commission’s budget to other purposes. Lavite, having no alleged liberty or property interest, did not establish any due process violation. View "Lavite v. Dunstan" on Justia Law