Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

Articles Posted in Constitutional Law
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Petitioner, a Guantanamo Bay detainee, raised two challenges to the constitutionality of the United States Court of Military Commission Review (CMCR). The court held that petitioner is not entitled to mandamus relief because this Court can consider his Appointments Clause and Commander-in-Chief Clause challenges on direct appeal, after the military commission renders a final judgment and the convening authority and the CMCR review it. Further, petitioner failed to demonstrate a “clear and indisputable” right to the writ. Therefore, the court denied petitioner's petition for writ of mandamus and prohibition. View "In re: Abd Al-Rahim Hussein Al-Nashir" on Justia Law

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Plaintiff, employed by WASA for sixteen years, filed suit against WASA on numerous grounds, including violating Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., by retaliating against him for opposing racially discriminatory employment practices. The district court dismissed the complaint and plaintiff appealed. The court concluded that, because plaintiff's complaint alleged facts that, if shown, would be at least sufficient to state a prime facie case of retaliation - and perhaps enough to survive summary judgment - it necessarily alleged facts sufficient to render his claim plausible at the motion to dismiss stage. Accordingly, the court reversed the dismissal. View "Harris v. DC Water and Sewer Auth." on Justia Law

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Plaintiff filed suit alleging that 18 U.S.C. 922(a)(9) and (b)(3) and implementing regulations are unconstitutional because the provisions, in effect, prohibit citizens not residing in any state from purchasing firearms. At issue was whether a citizen who permanently resides outside the United States has a right under the Second Amendment to purchase a firearm for self-defense while he is temporarily visiting this country. In this case, the court concluded that there are too many unanswered questions regarding plaintiff’s particular situation even though he seeks to mount an as applied challenge. Accordingly, the court vacated the district court's grant of summary judgment in favor of the United States and remanded for trial. View "Dearth v. Lynch" on Justia Law

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Plaintiff filed suit against two police officers, alleging that they violated the Fourth Amendment and D.C. law because each officer assaulted her son and one killed him. The court concluded that there are genuine issues of material fact with respect to the actions of the officer who fired the fatal shots, thus making himself the only surviving eyewitness to the actual killing. Therefore, the court reversed the district court’s grant of summary judgment in his favor. The court affirmed the jury's verdict for the second officer. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Flythe v. District of Columbia" on Justia Law

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Plaintiff filed suit against Whole Foods, alleging mistreatment that amounted to discrimination based on his disability and his race. Plaintiff suffers from a cognitive disability due to traumatic brain injury. He alleged that Whole Foods employees mistreated him and eventually orchestrated his false arrest for theft and trespassing. The court dismissed the suit. The court concluded, however, that plaintiff's pleadings set out allegations sufficient to survive dismissal of his Americans with Disabilities Act (ADA), 42 U.S.C. 12182(a), claim. The court held plaintiff's Civil Rights Act of 1964 (CRA), 42 U.S.C. 2000a(a), claim in abeyance until he complies with the CRA notice provision. Accordingly, the court reversed the dismissal of both the ADA and CRA claims and remanded for further proceedings. View "Brown v. Whole Foods" on Justia Law

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Crossroads GPS, the beneficiary of a favorable decision by the Commission, moved to intervene as a defendant in a suit challenging the Commission’s ruling. The district court denied intervention, finding Crossroads’ interests were aligned with the FEC’s Office of General Counsel’s, which was defending the ruling. The court concluded that Crossroads has Article III standing because it has a concrete stake in the favorable agency action currently in place. The court rejected the Commission's argument that prudential standing prevents the court from hearing this case, because Crossroads' interest do not fall within the zone of interests the law protects, where the zone of interest has no applicability to an intervening defendant in this instance. The court further concluded that Crossroads easily met the minimal burden of showing inadequacy of representation and should be allowed to intervene as of right. Accordingly, the court reversed the judgment of the district court. View "Public Citizen v. FEC" on Justia Law

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Section 308(1) of the Immigration and Nationality Act of 1952, 8 U.S.C. § 1408(1), designates persons born in American Samoa as non-citizen nationals. Plaintiffs, individuals born in the United States territory of American Samoa, challenged section 308(1), as well as State Department policies and practices implementing the statute on Citizenship Clause grounds and under the Administrative Procedure Act, 5 U.S.C. 500 et seq. The district court dismissed the case for failure to state a claim upon which relief can be granted. On appeal, plaintiffs reassert their constitutional claim. The court concluded that, while the language of the Thirteenth Amendment may be broader than that found in the Citizenship Clause, this comparison yields no dispositive insight as to whether the Citizenship Clause’s use of the term “United States” includes American Samoa or similarly situated territories. Even assuming a background context grounded in principles of jus soli, the court is skeptical that the framers plainly intended to extend birthright citizenship to distinct, significantly self-governing political territories within the United States’s sphere of sovereignty - even where, as is the case with American Samoa, ultimate governance remains statutorily vested with the United States Government. The court held it anomalous to impose citizenship over the objections of the American Samoan people themselves, as expressed through their democratically elected representatives. Accordingly, the court affirmed the judgment. View "Tuaua v. United States" on Justia Law

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PLN filed a Freedom of Information Act (FOIA), 5 U.S.C. 552 et seq., request to the Bureau seeking all documents showing money the Bureau paid in connection with lawsuits and claims brought against it between January 1, 1996, and July 31, 2003. The Bureau subsequently withheld information pursuant to exemption 6 and 7(C) of FOIA. The district court granted summary judgment in favor of the Bureau. The court reversed, agreeing with PLN that the Bureau’s use of a categorical explanation for the redactions was improper because of the varied nature of the documents and of the individuals shielded from disclosure, and that the district court did not adequately balance the privacy and public interests at stake. Accordingly, the court reversed the district court’s grant of summary judgment and remand for further proceedings View "Prison Legal News v. Samuels" on Justia Law

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Petitioners seek review of EPA's final rule, which determined that supercritical carbon dioxide injected into Class VI underground wells for purposes of geologic sequestration is “solid waste” within the meaning of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6903(27). The court dismissed the petitions for review because petitioners lacked Article III standing. In this case, neither Southern nor Occidental can show any injury sufficient to satisfy the requirements of Article III; Carbon Sequestration Council lacks standing because Southern lacks standing; and American Petroleum Institute lacks standing because Occidental lacks standing. View "Carbon Sequestration Council v. EPA" on Justia Law

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After Abu Wa’el (Jihad) Dhiab, a detainee at Guantanamo Bay, went on a hunger strike, he was forcibly extracted from his cell and force-fed. The district court examined 32 classified videotapes of Dhiab's forcible cell extractions and force-feedings in order to grant Dhiab's motion to enjoin the government from forcibly extracting him from his cell and force-feeding him. At issue is the district court's grant of media organizations' motion to unseal and release the videotapes. The court concluded that, the district court’s decision did not terminate the action, and it does not qualify as an immediately appealable collateral order. Therefore, the court lacked jurisdiction. Further, this case does not present the extraordinary circumstances required for mandamus relief. Accordingly, the court dismissed the appeal for lack of jurisdiction and denied the request for a writ of mandamus View "Dhiab v. Obama" on Justia Law