Justia Constitutional Law Opinion Summaries

The Seventh Circuit affirmed the district court's dismissal of an action alleging the violation of the Equal Protection Clause of the Fourteenth Amendment because the county placed a disproportionate tax on commercial and industrial properties in Mattoon Township. The court analyzed plaintiffs' claim solely on comity principles and held that the district court appropriately abstained from hearing the action. View "Perry v. Coles County, Illinois" on Justia Law

Under the Prison Litigation Reform Act of 1995 (PLRA), “[n]o action shall be brought with respect to prison conditions under [42 U.S.C. 1983], … until such administrative remedies as are available are exhausted.” Ramirez, who is a Spanish speaker, sued administrators and officers of the Western Illinois Correctional Center under 42 U.S.C. 1983 for alleged constitutional wrongs. As a prisoner. he was subject to the PLRA’s exhaustion requirement. Western Illinois had administrative remedies available. Ramirez did not use those procedures in a timely fashion to complain about the issues raised in his federal action. Ramirez claimed that the existing grievance process was unavailable to him because they were described to him only in a language that prison officials knew he did not understand. The district court held an evidentiary hearing, then dismissed Ramirez’s complaint without prejudice. The Seventh Circuit reversed. Because no administrator or officer of Western Illinois ever informed Ramirez of its grievance process in a way that he might reasonably understand, that process was unavailable to him and he was excused from the PLRA’s exhaustion requirement. View "Ramirez v. Young" on Justia Law

Iowa closed the Iowa Girls State Training School. Palmer, Director of the Iowa Department of Human Services, subsequently contracted to use the Wisconsin Girls State Training School (Copper Lake). Plaintiffs claim that, since its 2011 opening, Cooper Lake “has had a very high turnover rate of employees,” leading to “over-worked and untrained staff” and has received criticism from Wisconsin judges regarding its “sordid” and “inhumane” treatment of juveniles. Iowa juvenile courts ordered Plaintiffs to be placed at Copper Lake in 2015. Both were 16 years old. Plaintiffs claim that Copper Lake subjected them to prolonged “isolation,” and that they received little or no educational instruction. Both attempted suicide. Plaintiffs also claim they were subjected to excessive force and that staff sprayed them with mace on multiple occasions. Plaintiffs sued under 42 U.S.C. 1983 for cruel and unusual punishment, excessive force, and deprivation of due process. The Seventh Circuit reversed the dismissal of their claims. The district court acted prematurely in deciding Palmer’s entitlement to qualified immunity at the motion to dismiss stage. At the time plaintiffs were allegedly in Palmer’s custody, isolation of pre-trial juvenile detainees not “reasonably related to a legitimate governmental objective”could rise to the level of a constitutional violation. On the record, it is impossible to determine whether such a constitutional violation occurred in plaintiffs’ cases. View "Reed v. Palmer" on Justia Law

Minerva, an Ohio‐based, family‐owned dairy company, produces Amish‐style butters in small, slow‐churned batches using fresh milk supplied by pasture‐raised cows. Minerva challenged Wisconsin’s butter‐grading requirement under the Due Process Clause, the Equal Protection Clause, and the dormant Commerce Clause. Wisconsin’s law applies to butter manufactured in‐state and out‐of‐state and provides that butter may be graded by either a Wisconsin‐licensed butter grader or by the USDA. Wisconsin’s standards are materially identical to the USDA’s standards. The district court rejected the challenges on summary judgment, holding that the statute is rationally related to Wisconsin’s legitimate interest in consumer protection and does not discriminate against out‐of‐state businesses. The Seventh Circuit affirmed. Consumer protection is a legitimate state interest; the butter‐grading requirement is rationally related to the state’s legitimate interest in “protect[ing] the integrity of interstate products so as not to depress the demand for goods that must travel across state lines.” The state presented some evidence that the statute effectively conveys consumer preferences. The statute does not violate the Equal Protection Clause simply because Wisconsin failed to implement mandatory grading for other commodities. Wisconsin’s butter‐grading law confers a competitive advantage on prospective butter-graders who live closer to testing locations but this geographical fact of life does not constitute discrimination against out‐of‐state applicants. View "Minerva Dairy, Inc. v. Harsdorf" on Justia Law

Gray worked in maintenance for the Vigo County Parks and Recreation Department, cleaning restrooms and directing volunteers. Some volunteers were completing court‐mandated community service; Gray was responsible for signing off on their time‐logs. Gray performed his job with a high degree of autonomy and worked independently of another maintenance specialist assigned to his park. Doe volunteered at that park to complete her court‐ordered community service. She alleges that Gray took her to the park’s restroom and told her that it required cleaning. After locking the door, Gray allegedly forced Doe to perform oral sex and digitally penetrated her vagina. Gray pleaded guilty to criminal confinement and official misconduct. There were a few prior incidents of misconduct by county employees over the past two decades. Some involved sexual misconduct but, apparently, none resulted in coerced sexual activity. One incident involved a vague comment about Gray made by a park visitor; Vigo County could not substantiate the allegation. Another involved inappropriate comments that Gray made to a coworker; Gray received a written reprimand, which caused him to correct his behavior. Doe sued Gray and Vigo County for damages under 42 U.S.C. 1983. The district court entered a default against Gray and granted the county summary judgment. The Seventh Circuit affirmed, finding that the county was neither vicariously liable for Gray’s wrongs nor directly liable for permitting them to occur. View "Doe v. Vigo County" on Justia Law

Santiago was charged with conspiracy to possess with intent to distribute 1000 grams or more of heroin and five or more kilograms of cocaine, 21 U.S.C. 846; distribution of heroin, 21 U.S.C. 841(a)(1); and money laundering, 18 U.S.C. 1956. Before trial, Santiago unsuccessfully moved to suppress phone recordings secured through a wiretap under the Omnibus Crime Control and Safe Streets Act of 1968, 18 U.S.C. 2510–2520. A jury convicted Santiago on all charges. The Seventh Circuit affirmed the ruling on the motion to suppress, rejecting arguments that the application incorrectly stated that the investigators did not know his identity, that the application failed to establish that the wiretap was necessary to obtain relevant evidence and that he made a substantial preliminary showing that the application contained a deliberate or reckless misstatement of material fact that required a hearing under Franks v. Delaware. The warrant application’s failure to identify Santiago by his name rather than simply by his nickname did not affect the issuing court’s probable‐cause analysis. The application also established that traditional investigative techniques had been employed, but were unlikely to uncover critical evidence about the targets. Santiago did not make the necessary showing to obtain a Franks hearing. View "United States v. Santiago" on Justia Law

Lincolnshire's Ordinance 15-3389-116 Section 4 bans union-security agreements within the village by forbidding any requirement that workers join a union, compensate a union financially or make payments to third parties in lieu of such contributions and bars any requirement that employees “be recommended, approved, referred, or cleared for employment by or through a labor organization.” Section 5 prohibits employers from making payments to unions on a worker’s behalf except under a “signed written authorization” that may be revoked by the employee at any time by written notice. The Ordinance provides civil remedies and criminal penalties for its violation. Unions sued, asserting preemption by the National Labor Relations Act (NLRA). The district court entered summary judgment, finding that all of the unions had standing to challenge the membership and fee provisions and the checkoff regulation (section 5), but that only one union could challenge the section 4 prohibition of hiring halls. The Seventh Circuit agreed. The district court also held that all three provisions were preempted and that the unions failed to state a claim under 42 U.S.C. 1983. The Seventh Circuit affirmed. Localities may not address the subjects of hiring halls or dues checkoffs. The authority conferred in 29 U.S.C. 14(b)), allowing states to bar compulsory union membership as a condition of employment, does not extend to political subdivisions. View "International Union of Operating Engineers v. Village of Lincolnshire" on Justia Law

An Illinois jury convicted Czech of first-degree murder and aggravated discharge of a firearm for his role in a gang-related drive-by shooting that resulted in the death of a 14-year-old bystander. Czech argued on direct appeal that his counsel was ineffective for failing to challenge the felony murder instruction that was submitted to the jury in conjunction with a general verdict. The Illinois Appellate Court determined that the felony murder instruction violated Illinois law, but concluded the error was harmless. The Supreme Court of Illinois declined further review. The federal district court denied 28 U.S.C. 2254 relief, reasoning that, although the conviction violated clearly established federal law, the error did not have a substantial and injurious effect on the verdict. The Seventh Circuit affirmed. In 2004, when the Illinois court affirmed the conviction, no Supreme Court precedent clearly established that a conviction entered on a general verdict was unconstitutional merely because the jury instructions included a legal theory that was invalid under state law Even subsequent law did not expressly hold that instructing a jury on multiple theories of guilt, one of which is legally improper, is a constitutional error. In addition, Czech is not entitled to relief because, even if constitutional error were shown, the error was harmless: a properly instructed jury would have delivered the same verdict. View "Czech v. Melvin" on Justia Law

Bradford was convicted of conspiracy to distribute and possess with intent to distribute controlled substances, 21 U.S.C. 841(a)(1), 846; transfer of a firearm to a felon, 18 U.S.C. 922(d)(1); two counts of distribution of cocaine base, 21 U.S.C. 841(a)(1), (b)(1)(B), (b)(1)(C); possession of marijuana with intent to distribute, section 841(a)(1), (b)(1)(D); and possession of a firearm as a felon, 18 U.S.C. 922(g)(1). The jury acquitted him of possession of a firearm in furtherance of a drug-trafficking crime. The Seventh Circuit affirmed, rejecting his challenge to the denial of his motion to suppress evidence recovered in a search of his home pursuant to a warrant. Bradford claimed that the warrant application relied on statements from a confidential informant but omitted information damaging to the informant’s credibility. The informant’s information was quite detailed and robustly corroborated with ample additional evidence from the ATF’s investigation. Considering the warrant application as a whole, the omission of facts bearing negatively on the informant’s credibility was not fatal to the probable-cause finding. The court also upheld the denial of his pretrial motion to exclude evidence that he used the firearms seized in the search or directed others to use them; Rule 403 is a balancing test and there was no plain error. View "United States v. Bradford" on Justia Law

Hrobowski was convicted of federal firearms offenses in 2006 and sentenced to 264 months’ imprisonment under the Armed Career Criminal Act, 18 U.S.C. 924(e) based on prior Illinois state‐law convictions: aggravated battery, second‐degree murder, aggravated discharge of a firearm, and aggravated fleeing from a police officer. Hrobowski first unsuccessfully moved to vacate his sentence under 28 U.S.C. 2255, alleging ineffective assistance of counsel; he then unsuccessfully sought authorization to file a successive petition alleging a "Brady" violation. He then filed an unsuccessful petition under Descamps and Alleyne. Hrobowski then sought authorization to file a successive section 2255 petition following the U.S. Supreme Court’s Johnson decision, invalidating ACCA’s residual clause. Petitions based on Johnson errors generally satisfy the requirement for filing a successive section 2255 petition: the Johnson decision was a new rule of constitutional law, and the Supreme Court made the rule retroactive. Hrobowski claimed that he was discharged from the second‐degree murder conviction in 1998 and from the aggravated discharge of a firearm conviction in 2002 and that his civil rights were fully restored. The Seventh Circuit affirmed denial of the petition. One prior conviction was based on the residual clause but the Johnson violation was harmless as Hrobowski had three other prior violent felonies. His claim that two of his other convictions should not be considered prior violent felonies because his rights were restored is procedurally barred. View "Hrobowski v. United States" on Justia Law