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

Appellants were arrested for speeding in excess of 30 mph above the posted speed limit and subsequently filed a class action on behalf of all individuals who have been arrested and subjected to criminal penalties for such speeding in the last three years. Appellants alleged that the district's traffic enforcement policies denied them the equal protection of law and thus violated the Fifth Amendment. Specifically appellants objected to the district's policy of subjecting motorists who speed in excess of 30 mph over the speed limit to different penalties, depending on how they were caught. The district court granted the district's motion to dismiss under Rule 12(b)(6). The court affirmed the district court's judgment, but on different grounds. The court held that appellants' claim lacked merit because their challenge could not survive rational basis review where the district's traffic policy neither burdened a fundamental right nor targeted a suspect class. View "Dixon, et al. v. District of Columbia" on Justia Law

This case arose under the Freedom of Information Act (FOIA), 5 U.S.C. 552, where appellant challenged the CIA's Glomar response to his request for "all information or records relevant to... Sveinn B. Valfells." The court held that appellant failed to meet his burden to demonstrate that the CIA had officially acknowledged any record responsive to his FOIA request. Although the CIA confirmed that some unspecified "CIA-originated information" was redacted from an FBI report, appellant could not isolate any specific CIA record that had been officially acknowledged by the CIA. Accordingly, the judgment of the district court granting summary judgment to the CIA was affirmed. View "Moore, III v. CIA" on Justia Law

Defendant was convicted of serious drug offenses and sentenced to life imprisonment. On appeal, defendant contended that he received ineffective assistance of counsel when he declined the prosecution's plea deal proposal and instead went to trial. The court concluded that defendant could not show a reasonable probability that he would have pled guilty if he had been fully informed of the sentencing permutations and therefore could not show the required reasonable probability that the result of the proceeding would have been different. Accordingly, the court found no basis in the record to disturb the district court's credibility finding and affirmed the judgment. View "United States v. Franklin" on Justia Law

Appellant, an African-American female attorney in the Office of the Chief Counsel of the PBGC, filed suit in district court against the PBGC, claiming employment discrimination and retaliation in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e. Appellant appealed two issues: first, claims of race and gender discrimination and unlawful retaliation, arising out of four discrete episodes; second, a claim of retaliatory hostile work environment arising not only out of the four discrete episodes but also out of various other events as to which she raised claims that were time-barred. The court affirmed the district court's dismissal of appellant's claims of race and gender discrimination and of unlawful retaliation where the court did not believe that the PBGC's failure to remedy the various critiques and epithets to which appellant's fellow employees subjected her would have persuaded a reasonable employee to refrain from making or supporting charges of discrimination. The court held, however, that the district court erred to the extent that it categorically excluded her time-barred complaints in considering the hostile work environment claim, thus failing to employ the Nat'l R.R. Passenger Corp. v. Morgan analysis, including a determination of which acts exhibit the relationship necessary to be considered part of the same actionable hostile work environment claim. Accordingly, the court remanded for a determination of which, if any acts, should have been included under Morgan. View "Baird v. Gotbaum" on Justia Law

Plaintiff sued defendant, alleging that defendant had unlawfully discriminated against her in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff, a medical student who was diagnosed with dyslexia and a mild processing-speed disorder, contended on remand that the district court erred by failing to apply the 2008 amendments to the ADA and in relying on her prior academic achievement in assessing whether she suffered from a disability under the ADA. The court held that because plaintiff failed to show legal or clear factual error by the district court, the judgment was affirmed. View "Singh v. GW Univ. School of Medicine, et al." on Justia Law

Appellant and a co-defendant were extradited from Panama following their indictment on one count of conspiracy to distribute five kilograms or more of cocaine, intending or knowing that it would be imported into the United States from Columbia, Panama, Nicaragua, and elsewhere outside of the United States. Appellant challenged his conviction and sentence. The court held that the district court had jurisdiction over the charged conspiracy because appellant's extradition conformed with the governing treaty between the United States and Panama, and appellant waived his venue challenge by not raising it in the district court. Appellant identified no plain error affecting his substantial rights in the district court's acceptance of his guilty plea. Further, appellant failed to show he was denied effective assistance of counsel as would entitle him to reversal of his conviction. Because appellant presented no grounds for setting aside the judgment based on his guilty plea, the waiver of his right to appeal a below-Guidelines sentence set forth in the plea agreement was valid. Accordingly, the court dismissed the appeal of his sentence and affirmed the judgment of conviction View "In Re: Sealed Case" on Justia Law

Defendant sought reversal of his conviction by a jury for unlawful possession with intent to distribute cocaine and aiding and abetting, claiming trial evidentiary errors. Because defendant elicited testimony concerning the officer's law enforcement experience with drug trafficking in an attempt to demonstrate he was conditioned to see the benign items seized from defendant's bedroom as drug paraphernalia, and elicited his opinion regarding one of those items, defendant failed to show prejudice even assuming the testimony was improperly admitted. Circuit precedent confirmed defendant's other contentions were without merit. The district court neither abused its discretion in excluding expert evidence on the ultimate question in the case, nor erred in allowing the prosecutor to ask guilt-assuming hypothetical questions of a character witness testifying about her personal opinion. Accordingly, the court affirmed the conviction. View "United States v. Guerrero" on Justia Law

Defendant was convicted of conspiring with a male accomplice to extort money from an ex-lover, a doctor, by threatening to expose their brief extramarital affair to his wife and the medical licensing board. Defendant appealed her conviction on the grounds that the district court improperly denied her a duress instruction and improperly instructed the jury on venue. The court held that the district court correctly declined to instruct the jury on the affirmative defense of duress where no reasonable juror could have found defendant lacked a legal alternative to committing the crime. Further, the conspiracy instruction given by the district court did not require the jury to find that any overt act occurred in Washington, D.C., and defendant did not ask the district court to have the jury determine venue. Therefore, the district court did not commit plain error of any kind. Accordingly, the conviction was affirmed. View "United States v. Nwoye" on Justia Law

The District of Columbia appealed the denial of its motion to vacate a preliminary injunction pursuant to Rule 60(b)(5) of the Federal Rules of Civil Procedure. The injunction was issued in 1995 in response to a class action complaint alleging that the District of Columbia was violating the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to timely pay private providers of special education services and thereby jeopardizing students' special education placements. The district court denied the motion on two grounds: (1) dissolving the injunction and subsequent payment orders "would be disruptive to the status quo" and "counter-productive to the goal" of settling the case "in short order," and (2) the District of Columbia had "overstated both the relevance and the significance" of the Supreme Court's recent decision in Horne v. Flores. The court held that the district court failed to address changed circumstances, as Flores instructed, and reversed and remanded the case to the district court to determine whether, in view of changed circumstances, the District of Columbia's Rule 60(b)(5) motion should be granted. View "Petties, et al. v. District of Columbia, et al." on Justia Law

Defendant filed a petition for habeas corpus in the district court of the District of Columbia and the district court dismissed the petition for want of jurisdiction, reasoning that defendant was required to pursue his challenge in D.C. Superior Court rather than federal court because his D.C. Code 23-110 remedy was not inadequate or ineffective. Defendant subsequently applied for a certificate of appealability (COA). The court concluded that jurists of reason would not find defendant's claim that the district court had jurisdiction "debatable" because Diamen v. United States could not be reasonably read to bar defendant from bringing his federal constitutional claims in D.C. Superior Court under section 23-110. Accordingly, the court denied the COA. View "Ibrahim v. United States, et al." on Justia Law