Justia Constitutional Law Opinion Summaries

Drug task force officers in West Virginia observed a car with expired registration, dark window tint, and a malfunctioning taillight, driven by Cornelious Johnson—an individual known to them from a prior drug conviction and currently on federal supervised release. The officers watched as Johnson and his passenger interacted with a man, Jackie Byrd, at an apartment complex previously associated with drug investigations. Although the officers suspected a drug transaction, they did not witness any exchange of items. Shortly after, Tremayne Hawkins entered the back seat, and the car left the complex. Officer Stanley, informed by the task force, stopped the car for the observed traffic violations and, suspecting drug activity, separated and questioned the occupants about their interaction with Byrd. Citing minor inconsistencies in their answers, Stanley called for a K9 unit, which alerted to drugs. A subsequent search yielded a firearm on Hawkins, who admitted to being prohibited from possessing one due to a prior conviction.The United States District Court for the Northern District of West Virginia denied Hawkins’ motion to suppress the firearm, holding that the officers had reasonable suspicion to extend the stop based on the area’s reputation, Johnson’s prior conviction, the observed interaction with Byrd, and the inconsistent statements from the occupants.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Fourth Circuit held that none of the cited factors—alone or in combination—provided reasonable suspicion to extend the stop. The court emphasized that presence in an area associated with prior investigations, a dated conviction, innocuous interactions, and minor, reconcilable inconsistencies in statements did not collectively amount to reasonable suspicion of criminal activity. Accordingly, the Fourth Circuit reversed the district court’s denial of the suppression motion and remanded the case for further proceedings. View "US v. Hawkins" on Justia Law

A proposed constitutional initiative in Montana sought to require that Supreme Court and district court elections remain nonpartisan, reflecting a legal tradition in Montana since 1935. The proponent organization submitted both the initiative and a draft explanatory ballot statement to the Secretary of State, which was then reviewed by the Legislative Services Division. The organization’s draft statement explained the initiative would constitutionalize the existing statutory requirement, making future changes possible only by constitutional amendment.After the statutory review process, the Attorney General concluded the initiative met legal sufficiency but chose to substitute his own revised ballot statement, claiming the revision would improve clarity and better inform voters of the initiative’s effects. He did not detail any statutory deficiencies in the proponent's original statement. The proponent organization, joined by another organization interested in nonpartisan judicial elections, challenged the Attorney General’s authority to revise the statement without a written determination that the original was not clear or impartial. The Attorney General responded that only the proponent of the specific initiative could bring such a challenge.The Supreme Court of the State of Montana first found that only the proponent organization had statutory standing to pursue this challenge, dismissing the second organization from the proceeding. The Court then held that the Attorney General lacked authority to revise the proponent’s ballot statement because he had not made the required written determination that the original was statutorily noncompliant. The Court concluded that the proponent’s original statement was clear, impartial, and met statutory requirements. Accordingly, the Court certified the proponent’s original statement to the Secretary of State and ordered its use in the ballot process. View "MFIJ v. Knudsen" on Justia Law

A Texas law, Senate Bill 17, prohibits individuals who are domiciled in certain “designated countries,” including China, from acquiring interests in Texas real estate. The law defines “domicile” as a person’s true, fixed, and permanent home to which the individual intends to return whenever absent. Peng Wang, a Chinese citizen who has lived in Texas for sixteen years on an F-1 student visa, challenged the law’s constitutionality. Wang attends school in Texas, intends to remain in the state after graduation, and does not plan to return to China.The United States District Court for the Southern District of Texas dismissed Wang’s suit for lack of jurisdiction, holding that he lacked standing. The district court found that Wang was not domiciled in China based on his long-term residence and stated intentions to remain in Texas. The court also concluded that Wang faced no substantial risk of future enforcement of the statute against him, citing repeated in-court statements by the Texas Attorney General disavowing any intent to enforce the law against Wang.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. It affirmed the district court’s dismissal, holding that Wang lacked standing for two independent reasons. First, Wang failed to allege he was domiciled in China, so the statute did not arguably proscribe his conduct. Second, he did not demonstrate a credible threat of enforcement of the law, given the Attorney General’s in-court assurances and lack of any enforcement action or procedures targeting Wang. The Fifth Circuit therefore affirmed the dismissal for lack of jurisdiction. View "Wang v. Paxton" on Justia Law

A non-profit publisher mailed its legal resource book, The Habeas Citebook, to prisoners at a Washington state correctional facility. In 2018, the state's Department of Corrections implemented two policies: one prohibited inmates from possessing case law documents unless approved, and another barred possession of legal materials containing information about other Washington state inmates. Relying on these policies, prison officials at Coyote Ridge Corrections Center rejected and delayed delivery of the book. Although the Department’s Publication Review Committee later found the book permissible, the publisher was not notified of this reversal, and delivery to prisoners was significantly delayed—sometimes by over a year.The Human Rights Defense Center sued the prison superintendent and mailroom sergeant in the United States District Court for the Eastern District of Washington, alleging violations of the First and Fourteenth Amendments and seeking damages and injunctive relief. The district court initially granted summary judgment for the defendants on all claims, holding that the claims were either moot, failed on the merits, or did not establish personal liability. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and remanded, finding genuine disputes of material fact and instructing the district court to reconsider standing and liability issues. On remand, the district court again granted summary judgment for the defendants and denied requests for injunctive relief.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the defendants were entitled to qualified immunity against damages on the First and Fourteenth Amendment claims regarding the mail policies and lack of notice, as there was no clearly established precedent finding such policies unconstitutional. However, it reversed the district court’s denial of injunctive relief related to both the mail policy and notice procedures, finding that the appropriate legal standards had not been applied. The court also reversed the grant of qualified immunity on the delayed delivery claim, finding the right at issue clearly established, and remanded for further proceedings. View "HUMAN RIGHTS DEFENSE CENTER, INC. V. UTTECHT" on Justia Law

In this case, two licensed medical marijuana businesses in Arkansas challenged the validity of twenty-eight legislative amendments made by the Arkansas General Assembly to Amendment 98 of the Arkansas Constitution, which established a framework for medical marijuana use in the state. The businesses argued that these amendments were unconstitutional because they had not been submitted for voter approval, as they claimed was required, and that the amendments were not germane to the pertinent section as required by the constitutional language.The Pulaski County Circuit Court agreed with the plaintiffs, relying on the precedent set by Arkansas Game & Fish Commission v. Edgmon, and ruled that the General Assembly lacked authority to amend a voter-initiated constitutional amendment without submitting those amendments to a public vote. The court also found that the legislative amendments were not germane to section 23 of Amendment 98 and were therefore unconstitutional and void. The State of Arkansas appealed this ruling.The Supreme Court of Arkansas reviewed the case and reversed the circuit court’s decision. The court held that Article 5, section 1 of the Arkansas Constitution does grant the General Assembly authority to amend voter-initiated laws, including initiated constitutional amendments, by a two-thirds vote of both legislative chambers. The court explicitly overruled Arkansas Game & Fish Commission v. Edgmon, finding its reasoning inconsistent with the plain constitutional text. Additionally, the court determined that the word “section” in section 23(a) of Amendment 98 should be interpreted as “amendment,” so the germaneness requirement applies to the amendment as a whole. Consequently, the Supreme Court of Arkansas reversed and dismissed the lower court’s ruling. View "STATE OF ARKANSAS v. GOOD DAY FARM ARKANSAS, LLC" on Justia Law

Two individuals each pleaded guilty in separate cases to unlawful possession of controlled substances in Washington State. As part of their sentences, both were required to pay legal financial obligations (LFOs), which they partially satisfied through cash payments and through performing community service. Years later, following the Washington Supreme Court’s invalidation of the simple drug possession statute in State v. Blake, both individuals successfully moved to vacate their convictions and sought reimbursement for both the cash paid and the labor performed in community service that had satisfied portions of their LFOs.The trial courts vacated their convictions and reimbursed the cash payments but declined to reimburse for the value of the community service hours. Both individuals appealed. The Washington State Court of Appeals affirmed the trial courts’ decisions, holding that there was no substantive due process right to monetary reimbursement for community service work performed in lieu of LFO payments and that equal protection was not violated. The appellate court found that the appellants had not shown they were treated disparately from similarly situated individuals based on economic status, and even if there was disparate treatment, the decision to not reimburse for community service hours was rationally related to a legitimate governmental interest.The Supreme Court of the State of Washington reviewed the consolidated appeals. The court held that there is no constitutional right—fundamental or otherwise—to reimbursement for community service work performed in satisfaction of court-imposed financial obligations when convictions are later invalidated. The court found no disparate treatment based on economic status and therefore no actionable equal protection claim. The decision of the Court of Appeals and the trial courts was affirmed. View "State v. Danielson" on Justia Law

A female senior administrator at a Mississippi public university, who had served as Vice President and Chief of Staff since 2017, alleged that she was not hired for the position of university president on two occasions, in 2020 and 2023, despite her extensive qualifications and expressed interest. In 2020, following the resignation of the then-president, the university’s governing board appointed a less-experienced male interim president without conducting a search or soliciting applications, even though the plaintiff had managed university affairs in the president’s absence. After the interim president was placed on administrative leave in 2023, the board began a new search. The plaintiff applied but was denied an interview; instead, the board selected another male candidate with less experience, who had not applied for the position.The plaintiff filed suit against the board members in their individual capacities, alleging sex discrimination under the Equal Protection Clause via 42 U.S.C. § 1983, as well as Title VII claims. The United States District Court for the Southern District of Mississippi dismissed all claims against the individual board members except for the § 1983 equal protection claim regarding the 2023 hiring decision. The district court found that the plaintiff stated a prima facie case of sex discrimination and that the right to be free from such discrimination was clearly established, thus denying the defendants’ motion to dismiss based on qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The court held that the plaintiff adequately pleaded a violation of clearly established equal protection rights, including allegations that each defendant took individual actions causing the asserted harm. The Fifth Circuit therefore affirmed the district court’s denial of the motion to dismiss as to the § 1983 equal protection claim arising from the 2023 hiring decision. View "Jackson v. Duff" on Justia Law

Federal and state law enforcement officers executed a search warrant at the home and business of George Peterson, a federally licensed firearms dealer operating out of his residence in Louisiana. The warrant was supported by an affidavit detailing months of investigation by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), including undercover purchases where Peterson failed to report firearm sales as required and sold firearms under circumstances suggesting knowledge of illegal transactions. During the search, agents discovered a homemade, unregistered firearm suppressor in Peterson’s closet safe. The suppressor lacked a serial number and was not registered as required by the National Firearms Act (NFA).A grand jury in the United States District Court for the Eastern District of Louisiana indicted Peterson for possession of an unregistered suppressor in violation of the NFA. Peterson moved to dismiss the indictment, arguing the NFA’s registration scheme violated his Second Amendment rights as applied to him, and also moved to suppress the evidence, claiming the search violated the Fourth Amendment. The district court denied both motions. Peterson entered a conditional guilty plea, reserving the right to appeal those rulings. He was sentenced to twenty-four months’ imprisonment.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s decisions. The court held that, assuming suppressors are protected by the Second Amendment, the NFA’s “shall-issue” licensing and registration regime is presumptively constitutional under New York State Rifle & Pistol Association v. Bruen and related precedent. Peterson failed to show that the NFA’s requirements denied him his rights or were applied abusively. Regarding the motion to suppress, the court found that the good-faith exception to the exclusionary rule applied because the officers reasonably relied on a warrant issued by a magistrate judge, even if probable cause was disputed. Thus, both denials were affirmed. View "United States v. Peterson" on Justia Law

Federal agents learned that a previously convicted felon arranged the sale of a World War II-era Russian machinegun, which he acknowledged could not be lawfully transferred. The defendant, though not in physical possession of the weapon, set up the transaction between an undercover federal agent—posing as a firearms and drug trafficker—and a third party who actually had the gun. The agent and the defendant traveled together to complete the purchase, and the defendant was later arrested.The United States District Court for the District of Oregon presided over the prosecution. A grand jury indicted the defendant for both possessing or transferring a machinegun under 18 U.S.C. § 922(o) and for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). Before trial, the defendant moved to dismiss the machinegun charge, arguing that the Supreme Court’s decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen required invalidation of the statute, and also that the statutory exemption in § 922(o)(2)(A) applied since the transfer was to a federal agent. The district court denied the motion, relying on Ninth Circuit precedent in United States v. Henry, which held that machineguns are not protected by the Second Amendment, and on earlier cases interpreting the statutory exemption narrowly. At trial, the jury acquitted on the felon-in-possession count but convicted on the possession or transfer count, and the district court sentenced the defendant to twenty-seven months in prison.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the conviction. The court held that the exemption in § 922(o)(2)(A) for transfers to the United States does not apply to transfers to undercover agents unless the transfer is authorized by the government for its benefit. The court also held that its prior decision in Henry remains binding, and that § 922(o) does not violate the Second Amendment. View "USA V. KITTSON" on Justia Law

A police officer in Des Moines, Iowa attempted to stop a vehicle driven by Dylan Pettyjohn for lacking license plates or a temporary registration. Pettyjohn fled, leading the officer on a high-speed chase through a residential area before crashing. He then ran from the vehicle, discarding a loaded revolver and a fanny pack containing 54 fentanyl pills, $389 in small bills, marijuana, and about 85 grams of methamphetamine. A search of his vehicle yielded a digital scale with white residue, more marijuana, and shell casings. Pettyjohn was arrested, and a federal grand jury indicted him on multiple counts related to drug possession with intent to distribute, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm.The United States District Court for the Southern District of Iowa denied Pettyjohn’s motion to dismiss the felon in possession charge, rejecting his argument that 18 U.S.C. § 922(g)(1) violated the Second Amendment. The court also allowed limited admission of his prior felony convictions for impeachment purposes, after an agreement between Pettyjohn and the government. At trial, Pettyjohn moved for acquittal based on insufficient evidence, but the district court found the evidence sufficient and denied the motions. The jury found Pettyjohn guilty on all counts, and the court sentenced him to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirmed the district court’s evidentiary rulings under Rules 404(b) and 609, and upheld the constitutionality of § 922(g)(1) based on circuit precedent. The Eighth Circuit held that the evidence was sufficient to support the convictions, the district court did not abuse its discretion in admitting prior conviction evidence, and § 922(g)(1) is constitutional. The judgment of the district court was affirmed. View "United States v. Pettyjohn" on Justia Law