Justia Constitutional Law Opinion Summaries

Beauchamp had cerebral palsy. Her mother found Beauchamp unresponsive and called 911. Minutes later, four “First Responders” arrived and attempted CPR and ventilation. After about 30 minutes, they discontinued those efforts and declared her dead. They also called a doctor to obtain permission to stop trying resuscitation, although they had stopped resuscitative efforts five minutes earlier. Numerous medical indicators showed that Beauchamp was not dead—her capnography indicated continued respiration, her cardiac monitor showed electrical activity, and her breathing and pulse were perceptible to her family members. Despite inquiries by Beauchamp’s family members, police officers, and a funeral home employee, the First Responders repeated that Beauchamp was dead, explaining the signs of life as reactions to medication. The funeral home employee placed Beauchamp in a body bag and went to the funeral home. An embalmer saw Beauchamp gasping for air with her eyes open and her chest moving and called 911. At the hospital, doctors determined that Beauchamp was alive but had suffered an anoxic brain injury. Beauchamp remained on a ventilator in a vegetative state and died weeks later.The Sixth Circuit affirmed the dismissal of a suit under 42 U.S.C. 1983, alleging deliberate indifference to Beauchamp’s serious medical need. The individual defendants are entitled to qualified immunity and the city is not liable for any constitutional violation. View "Linden v. City of Southfield, Michigan" on Justia Law

D.B. left a Detroit and believed he was being followed by a silver sedan. At 1:41:01 a.m., a traffic camera captured D.B. driving through an intersection, followed by the silver sedan less than a minute later. Minutes later, about 2-½ miles away, an individual in a silver sedan shot D.B. Surveillance video captured muzzle flashes coming from a silver sedan described as “look[ing] like a Chevy Malibu.” The only silver sedan that could be placed in D.B.’s proximity around the time of the shooting was Smith’s Chevy Malibu. D.B. later picked Smith out of a photographic lineup as someone he had a “beef [with] in the past.”Smith’s car was tagged in Michigan’s Law Enforcement Information Network, with a warning that the car’s occupants were armed. Days later, an officer stopped Smith’s car and frisked Smith for weapons. Smith stated there was a gun in a case in the car. The trooper performed a “protective sweep” of the areas within a driver’s reach and found a handgun with a chambered bullet and a baggie containing fentanyl and heroin. Smith unsuccessfully moved to have the evidence suppressed as fruit of an unreasonable search. The Sixth Circuit affirmed the denial of the motion. The police had reasonable suspicion to stop Smith and perform a limited search. View "United States v. Smith" on Justia Law

Coopwood has bipolar disorder and schizophrenia. She was institutionalized several times from 2010-2017. On August 13, 2017, Coopwood (six months pregnant) stopped taking her antipsychotic medications because of concerns about potential effects on the fetus. Coopwood fatally stabbed her mother and was ultimately found “guilty but mentally ill.”In pretrial custody, Coopwood, not taking her antipsychotic medications, was repeatedly screened and denied any history of mental health treatment. Employees, aware of Coopwood’s history of inpatient psychiatric care, did not raise concerns. Coopwood alleges that, in August 2017, Jailer Watts dragged her to her cell and kicked Coopwood in the stomach, after which she suffered cramping with a bloody discharge from her vagina. She was hospitalized several times in August and September. On October 19, she was seen by a psychiatrist, Haddad, who determined that Coopwood had been psychotic for an unknown period and seemed unaware of her circumstances. On October 22, Coopwood, exhibiting bizarre behavior, was forcibly given antipsychotic medications. She was readmitted on November 8, reporting contractions. Labor was induced. Coopwood’s baby was stillborn. Coopwood contends that she attempted to file a grievance but that her verbal requests were ignored.Coopwood’s suit, alleging excessive force and deliberate indifference to her medical needs, was dismissed. The Sixth Circuit reversed. Defendants failed to establish the absence of a genuine dispute of material fact as to whether the Jail’s staff thwarted Coopwood’s attempts to exhaust her administrative remedies. View "Coopwood v. Wayne County, Michigan" on Justia Law

Miller, who describes himself as “an active wine consumer,” asserts that he wants to order wine from out-of-state retailers and would like to be able to buy wine in other states and transport that wine back into Ohio for his personal use. House of Glunz is an Illinois wine retailer and alleges that it wishes to ship wine directly to Ohio consumers but cannot. Miller and Glunz challenged the constitutionality of Ohio liquor laws preventing out-of-state wine retailers from shipping wine directly to Ohio consumers and prohibiting individuals from transporting more than 4.5 liters of wine into Ohio during any 30-day period.The district court held that the Direct Ship Restriction is constitutional under binding Sixth Circuit precedent; the Director of the Ohio Department of Public Safety is entitled to Eleventh Amendment immunity from the claims; and the plaintiffs lack standing to challenge the Transportation Limit. The Sixth Circuit affirmed the Director of the Ohio Department of Public Safety’s Eleventh Amendment immunity, reversed with respect to the Direct Ship Restriction and the plaintiffs’ standing to challenge the Transportation Limit. On remand, the district court shall determine whether the challenged statutes “can be justified as a public health or safety measure or on some other legitimate nonprotectionist ground,” and whether their “predominant effect” is “the protection of public health or safety,” rather than “protectionism.” View "Block v. Canepa" on Justia Law

Michigan State University's “COVID directives,” included a requirement that all employees receive a vaccine by August 31, 2021, even those who worked remotely. The policy included religious and medical exemptions. Medical exemptions were limited to “CDC-recognized contraindications and for individuals with disabilities.” It did not provide an exemption based on immunity acquired from a COVID-19 infection. The plaintiffs all tested positive for COVID-10 and claimed that, based on their natural immunity, it was medically unnecessary for them to be vaccinated. They did not comply with the policy; one was terminated, one was placed on unpaid leave, and one received a religious exemption.Their suit claimed violations of their constitutional rights to bodily autonomy and to decline medical treatment, alleging that MSU cannot establish a compelling governmental interest in overriding those constitutional rights; the policy constitutes an unconstitutional condition on continued state employment; and the policy contradicts the Emergency Use Authorization (EUA) statute, 21 U.S.C. 360bbb-3. The Sixth Circuit affirmed the dismissal of the suit. It is sufficient that MSU could rationally believe that requiring the vaccine for naturally immune individuals would further combat COVID-19 on its campus. The plaintiffs did not adequately explain how receiving a vaccine violates a fundamental right, which would invoke a higher level of scrutiny. The EUA is meant to ensure patients’ consent to the pharmaceutical they are receiving and does not mean that MSU cannot require vaccination as a term of employment. View "Norris v. Stanleys" on Justia Law

Tennessee enacted the Prohibition on Medical Procedures Performed on Minors Related to Sexual Identity, citing concerns that gender dysphoria treatments “can lead to the minor becoming irreversibly sterile, having increased risk of disease and illness, or suffering adverse and sometimes fatal psychological consequences” while less risky, non-irreversible treatments remain available. Prohibited procedures include surgically removing, modifying, or entering into tissues, cavities, or organs and prescribing or dispensing any puberty blocker or hormone with exceptions for treating congenital defects, precocious puberty, disease, physical injury, and continuation of ongoing treatment. It provides for professional discipline of healthcare providers and creates a private right of action.The district court entered a preliminary injunction, finding that the challengers lacked standing to contest the surgery ban but that the ban on hormones and puberty blockers infringes the parents’ “fundamental right” to direct their children’s medical care, improperly discriminates on the basis of sex, that transgender persons constitute a quasi-suspect class, and that the state could not satisfy the necessary justifications.The Sixth Circuit stayed the injunction, finding that Tennessee is likely to succeed on appeal. The district court erred in its facial invalidation of the law, as opposed to an as-applied invalidation. “Life-tenured federal judges should be wary of removing a vexing and novel topic of medical debate from the ebbs and flows of democracy by construing a largely unamendable federal constitution to occupy the field.” A right to new medical treatments is not “deeply rooted" in history and traditions. Tennessee could rationally exercise caution before permitting irreversible medical treatments of children. View "L. W. v. Skrmetti" on Justia Law

Officers discovered Brewer’s naked body tied to his bed frame; he had been shot twice. The case went cold for several years before an inmate told officers that Miller and Hall and two women had set up a threesome with Brewer in order to rob him. DNA found at the scene did not implicate either woman. The women implicated Martin. Officers knew the story was false but nonetheless interviewed Martin; the interview was not recorded. Martin, who claimed to have been "very high" on the night of the murder, waffled between denying any involvement and other stories. Officers falsely told her that her DNA was found at the scene and implied her children could be taken away. Martin failed a polygraph examination. Martin was told that “she’[d] walk” if she revealed the killer but that if she did not implicate anybody else, she would “go down.” Eventually, with a plea agreement, she implicated Miller. Martin repeatedly attempted to recant. Kentucky indicted Miller but eventually dropped the charges.Miller filed suit (42 U.S.C. 1983) for malicious prosecution, fabrication of evidence, destruction of exculpatory evidence, due process violations, and conspiracy. The Sixth Circuit affirmed summary judgment for the defendants. Because the conduct at issue was in furtherance of genuine prosecutorial interests, the prosecutor has absolute immunity for his actions, including ordering the destruction of evidence and purported thwarting of a court order. The other defendants were entitled to qualified immunity. View "Price v. Montgomery County" on Justia Law

Tennessee law enforcement was alerted to a drug distribution operation and executed a search warrant that resulted in the seizure of over 200 grams of pure meth. Agents executed additional warrants and intercepted phone calls. Twelve individuals, including Reed and Brown, were charged with conspiring to distribute and to possess with the intent to distribute, at least 50 grams of meth. According to trial testimony by the law-enforcement agents, Brown and Reed both admitted to purchasing meth on numerous occasions and named several others. Four co-conspirators testified at trial. The parties agreed, and the judge confirmed, that Brown should not be mentioned during testimony to avoid the possibility of incriminating him. An officer read directly from his report, inadvertently mentioning Brown before stopping midsentence. Brown’s counsel made no objection. A joint stipulation was entered regarding the quantity and purity of the meth seized from various codefendants. No meth was seized from either Brown or Reed, who asked the district court to instruct the jury that “a conspiracy requires more than just a buyer-seller relationship.”The Sixth Circuit affirmed the convictions of Brown and Reed but vacated their 360-month sentences. The defendants’ request for a buyer-seller jury instruction was appropriately denied. The district court procedurally erred when calculating the defendants’ Guidelines ranges; it provided no basis to conclude that at least 4.5 kilograms of the meth distributed was actual meth. View "Reed v. United States" on Justia Law

Ohlinger, booked into the jail (SEORJ) as a pretrial detainee for burglary, reported a history of bipolar disorder and depression and that she used intravenous heroin daily. She indicated no history of seizures and reported no signs of physical trauma or illness. In the following days, Ohlinger did not report any medical problems. On June 25, at 6:57 a.m., Ohlinger, walking in the common area, appeared to become disoriented and fell off a bench. Officers Lowery and Jarvis responded. Nurse Gray found no evidence to support inmates’ statements that Ohlinger had a seizure and hit her head. She was returned to her cell. At 7:07 a.m., Lowery and Jarvis responded to a call and, seeing Ohlinger had urinated on herself, escorted Ohlinger to the medical unit. Gray again examined Ohlinger. Lowery and Jarvis returned Ohlinger to her cell to await a blood test. At 9:12 a.m., an inmate discovered Ohlinger, unresponsive. Gray used a portable defibrillator and began CPR. At 9:28 a.m., paramedics transported Ohlinger to the hospital, where she died. An autopsy identified the cause of death as seizure activity due to a subarachnoid hemorrhage and subdural hematoma of undetermined etiology. There was no evidence of skull fracture or contusions.In a suit under 42 U.S.C. 1983, the district court granted summary judgment to Gray, Lowery, and Jarvis. The Sixth Circuit reversed as to Gray and otherwise affirmed. A reasonable jury could find that Gray acted recklessly, not negligently, in the face of unjustifiably high risk to Ohlinger’s health. Gray’s observations of Ohlinger, information provided by other jail officials and inmates, and SEORJ’s policies should have led Gray to seek care from a doctor or hospital. View "Mercer v. Athens County, Ohio" on Justia Law

Spectrum contracts with Michigan to house children who are ordered to be detained in facilities “similar to a prison setting.” The children are completely restricted in their movements. The state requires Spectrum to monitor them on a 24/7 basis. A court ordered the detention of 15-year-old Quintana at Spectrum’s facility on August 24, 2018. Quintana struggled with depression, anxiety, and difficulty sleeping, among other things. On September 11, 2018, Quintana took his life while alone in his bedroom. No one checked his room in the 45 minutes between the last time he was seen alive and when his body was found, violating a contractual requirement that Spectrum conduct “eye-on checks” every 15 minutes when the children are “outside of the direct supervision of staff.” Spectrum had a policy or custom of skipping many eye-on checks and falsifying supervision logs to reflect that the checks had been performed.Quintana’s estate sued Spectrum under 42 U.S.C. 1983, alleging that Spectrum functioned as a state actor and violated Quintana’s Eighth and Fourteenth Amendment rights. The Sixth Circuit reversed the dismissed the dismissal of the suit. The complaint contains adequate facts to establish that Spectrum is a state actor. Spectrum was allegedly engaged in a public function similar to a correctional institution, a traditionally exclusive state function. View "Nugent v. Spectrum Juvenile Justice Services" on Justia Law