Justia Constitutional Law Opinion Summaries

A religious nonprofit organization sought to purchase a former university campus property after being selected as the winning bidder in a competitive process conducted by a state university system. Following the public announcement of the award, there was significant public opposition to the sale, particularly due to the religious nature of the winning bidder. Two unsuccessful bidders filed administrative protests, raising both procedural and substantive objections, including criticism of the university's decision to sell to a religious organization. The university's designated official initially denied these protests, but upon further internal review, a higher-level administrator determined that a flaw in the bid evaluation process—specifically, the failure to consider cost-saving proposals for existing infrastructure—warranted rescinding the award and restarting the process. In the new round, the property was awarded to a different bidder who scored higher under revised criteria.The original winning bidder, the religious organization, challenged the university's decision in the United States District Court for the District of Maine, alleging violations of the Equal Protection and Free Exercise Clauses of the U.S. Constitution. The district court denied the plaintiff’s motions for a temporary restraining order and a preliminary injunction, finding that the plaintiff failed to show a likelihood of success on the merits of either claim. The court credited testimony that the university’s decision was motivated by cost-saving considerations rather than religious bias, and found no clear evidence of procedural irregularity or pretext.On appeal, the United States Court of Appeals for the First Circuit reviewed the denial of the preliminary injunction for abuse of discretion. The Court affirmed the district court’s decision, holding that the lower court applied the correct legal standards and did not clearly err in its factual findings. The Court concluded that the plaintiff failed to demonstrate a likelihood of success on the merits of its constitutional claims. View "Calvary Chapel Belfast v. University of Maine System" on Justia Law

A Michigan physician was charged with twenty-one counts of unlawfully distributing controlled substances to his patients. Over several years, he prescribed large quantities of medications to individuals who exhibited signs of drug-seeking behavior, failed drug screens, engaged in doctor shopping, and requested specific highly abused drugs. The physician often ignored red flags such as patients’ substance abuse histories and failed to perform required physical examinations. His practices led to at least one patient’s overdose death. Evidence at trial included expert testimony that his prescribing was inappropriate and outside the usual course of professional practice.The case was first tried in the United States District Court for the Eastern District of Michigan, but the initial trial ended in a mistrial. A retrial was delayed and declared a mistrial due to the COVID-19 pandemic. The third trial proceeded in March 2023, with the district court requiring witnesses to wear masks while testifying. After a 13-day trial, a jury convicted the physician on all counts. Post-trial motions for acquittal or a new trial were denied, and the physician was sentenced to twenty years on the count involving death, with concurrent sentences on the remaining counts. He appealed, challenging the sufficiency of the evidence, the authority of the Attorney General to regulate prescribing, the jury instructions, and the mask mandate’s constitutionality.The United States Court of Appeals for the Sixth Circuit reviewed the appeal. It held that sufficient evidence supported the convictions, the jury instructions accurately reflected the law and were not misleading or confusing, and the district court’s mask mandate did not constitute reversible error under the Confrontation Clause. The court found no plain error in the regulatory and constitutional challenges and affirmed the district court’s judgment in its entirety. View "United States v. Shelton" on Justia Law

Plaintiffs had their property taken by the Commonwealth of Puerto Rico through eminent domain. They received over two million dollars in compensation, including interest accrued up to the time of payment. However, they alleged a second violation occurred when the court-administered disbursement process failed to notify them of further accrued interest and deducted a 15% administrative fee from that interest. They challenged these practices as unconstitutional takings and violations of due process, seeking declaratory and equitable relief against the Administrator of the Administration of Tribunals.The United States District Court for the District of Puerto Rico initially dismissed most claims, finding plaintiffs lacked standing because they had not alleged an attempt to withdraw the accrued interest, making their injury speculative. After reconsideration, the court revived the claim challenging the deduction of administrative fees, but limited relief to prospective injunctive relief due to Eleventh Amendment constraints. The court ultimately granted summary judgment to the defendant, finding the administrative fee reasonable and not an unconstitutional taking, as plaintiffs provided no evidence to the contrary.The United States Court of Appeals for the First Circuit reviewed the case and confronted jurisdictional issues arising from Puerto Rico’s Title III bankruptcy under PROMESA. The court held that the administrative fee claim was void for violating the automatic stay provisions, as it amounted to a demand for property of the debtor (the Commonwealth), and dismissed that portion of the appeal. Regarding the interest claim, the court affirmed the district court’s dismissal, ruling plaintiffs lacked standing because they failed to allege they sought disbursement or challenged existing procedures. The First Circuit thus dismissed the appeal from summary judgment and affirmed the district court's dismissal. View "Hernandez-Castrodad v. Steidel-Figueroa" on Justia Law

The case concerns a late-night car crash in Bloomington, San Bernardino County, where Steven Richard Castro collided with a parked vehicle, injuring its occupant. Neighbors restrained Castro, who tried to flee, and emergency personnel transported him to the hospital due to his combative behavior. CHP Officer Pope, stationed at the hospital on another matter, was notified about Castro's arrival and subsequently observed Castro sedated and unresponsive in the ER. Pope noted the smell of alcohol and, after gathering information from witnesses and the victim, arrested Castro on suspicion of DUI causing injury. Without seeking a warrant, Pope ordered a blood draw, relying on implied consent law. The blood test showed a high BAC.In the San Bernardino County Superior Court, Castro moved to suppress the blood test results, arguing that a warrant should have been obtained. The magistrate denied the motion, citing exigent circumstances per Mitchell v. Wisconsin, reasoning that Officer Pope’s time in the hospital justified the warrantless blood draw. Castro renewed his suppression request in a pretrial motion, but the court again found the officers’ actions constitutional based on the totality of circumstances and Castro’s unconsciousness, leading Castro to enter a no contest plea.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the record did not support a finding of exigency sufficient to excuse the failure to obtain a warrant for the blood draw. The court emphasized that Mitchell v. Wisconsin does not create a categorical rule for unconscious DUI suspects and, following its reasoning in People v. Alvarez, found no evidence that obtaining a warrant would have interfered with other pressing duties. The judgment was reversed, and the matter remanded with directions to grant the suppression motion and permit Castro to withdraw his plea. View "People v. Castro" on Justia Law

A man was convicted for malice murder and related offenses stemming from a murder-for-hire scheme in 2000, where the victim was killed in her Georgia apartment. The prosecution argued that the murder was orchestrated by the victim’s father-in-law, who opposed her marriage, and that the appellant was the hired killer, with testimony from accomplices and witnesses supporting this theory. The appellant's trial was marked by difficulties in securing expert witnesses and conducting mitigation investigations due to funding shortfalls in Georgia’s indigent defense system, which hampered his defense’s ability to prepare. Eventually, he was convicted on several counts and initially sentenced to death, with subsequent modifications after further proceedings.After conviction, the appellant’s attorneys from the Capitol Defender’s Office filed a motion for a new trial, later amended and supplemented by other attorneys from the same office. The Superior Court of Fulton County partially granted the motion, ordering a new trial solely on the issue of “mental retardation” for sentencing purposes, due to the late development of evidence related to this issue, which was attributed to a breakdown in indigent defense funding. Later, a new judge re-sentenced the appellant to life without parole in accordance with that order. Other grounds for a new trial were denied, and the appellant retained private counsel to pursue his appeal.The Supreme Court of Georgia reviewed the case and determined that, because this appeal was the appellant’s first opportunity to raise ineffective assistance of counsel claims (having been continuously represented by the same public defender’s office), the record was insufficiently developed on this issue. The Court vacated the trial court’s judgment in part and remanded the case for an evidentiary hearing on the ineffective assistance claims. Other claims regarding denial of a continuance and competency to stand trial were rejected, as the appellant failed to show harm or preserve those issues. Judgment was affirmed in part and vacated and remanded in part. View "CLARK v. THE STATE" on Justia Law

The case involves a defendant who was convicted of malice murder and other related crimes following the fatal shooting of a convenience store owner late at night. Surveillance footage captured the movements of three assailants before and after the shooting, and law enforcement linked the defendant to the crime through evidence including a matching vehicle, clothing, cell phone records, and an anonymous tip. During the investigation, police obtained multiple search warrants that led to the seizure of various pieces of evidence, such as cell phones and ammunition. The defendant challenged the legitimacy of these warrants, arguing that the affidavits supporting them included material misrepresentations and omissions by police.After being indicted and tried in the Superior Court of DeKalb County, the defendant was convicted on all counts and sentenced to life imprisonment without parole for malice murder, with additional consecutive sentences for other offenses. The trial court merged some counts and vacated others as required by law. The defendant moved for a new trial, which was denied after a hearing. He then appealed, arguing that the trial court erred in denying his motion to suppress evidence due to alleged false statements in the search warrant affidavits and that his right to confront witnesses was violated by the admission of substitute expert testimony.The Supreme Court of Georgia reviewed the case. The court held that the trial court had not properly applied the standard from Franks v. Delaware for assessing whether false statements in warrant affidavits were made knowingly, intentionally, or with reckless disregard for the truth. The Supreme Court of Georgia vacated the trial court’s judgment on the motion to suppress and remanded the case for further proceedings consistent with the proper Franks analysis, leaving other issues unresolved pending that review. View "MILLER v. THE STATE" on Justia Law

A pharmaceutical manufacturer participating in the federal 340B Drug Pricing Program challenged a Missouri law that prohibits manufacturers from restricting the delivery of discounted 340B drugs to contract pharmacies associated with covered entities. The manufacturer argued that its policy of limiting deliveries to only one contract pharmacy conflicted with Missouri’s statute, which requires delivery to all contract pharmacies designated by covered entities. The manufacturer sought declaratory and injunctive relief, claiming the Missouri statute violated the dormant Commerce Clause and was preempted by federal law.The United States District Court for the Western District of Missouri granted a motion to dismiss the manufacturer’s preemption claims, finding Missouri’s statute did not conflict with federal patent or drug exclusivity laws or the 340B Program, and that Eighth Circuit precedent foreclosed the field preemption argument. The court denied the motion to dismiss the dormant Commerce Clause claim, but ultimately denied the manufacturer’s motion for a preliminary injunction, concluding the manufacturer was unlikely to succeed on the merits of its claims, had not shown irreparable harm, and that the balance of equities and public interest weighed against preliminary relief.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of preliminary injunction under the abuse of discretion standard. The appellate court affirmed the district court’s decision, holding that the Missouri statute regulates only in-state delivery of 340B drugs and does not impermissibly control extraterritorial commerce, discriminate against interstate commerce, or impose excessive burdens in relation to local benefits. The court also found the manufacturer’s preemption claims foreclosed by Eighth Circuit precedent and concluded the statute is neither field nor conflict preempted. The district court’s denial of preliminary injunctive relief was affirmed. View "Novartis Pharmaceuticals Corp. v. Hanaway" on Justia Law

Texas Tobacco Barn operated a laboratory and retail shop in Lubbock, Texas, manufacturing and selling e-liquids and vape products. After applying for authorization to sell over 2,200 vape products, including Barn Brewed Beetle Juice e-liquids, the FDA denied approval and warned that these products were considered “adulterated” and “misbranded.” Despite assurances from Texas Tobacco Barn that it would cease sales, a subsequent FDA inspection revealed continued sale of unauthorized products. The FDA initiated proceedings seeking a civil penalty of $19,192 for violations.The enforcement action began with an administrative hearing before an HHS administrative law judge (ALJ), who reviewed evidence including inspection photos and testimony from an FDA inspector. Texas Tobacco Barn admitted that the e-liquids lacked FDA authorization but disputed the inspector’s findings and challenged the FDA’s regulatory authority. The ALJ concluded that the FDA proved its case by a preponderance of the evidence and imposed the civil penalty. On appeal, the HHS Departmental Appeals Board affirmed the ALJ’s ruling, agreeing the ALJ lacked jurisdiction to address constitutional challenges but offering advisory comments on those defenses.Reviewing the agency’s final decision, the United States Court of Appeals for the Fifth Circuit considered Texas Tobacco Barn’s statutory and constitutional arguments. The court rejected the nondelegation challenge, citing its own precedent and Supreme Court guidance clarifying FDA’s explicit authority to regulate vape products. However, the Fifth Circuit held that the administrative process violated Texas Tobacco Barn’s Seventh Amendment right to a jury trial. The court determined that civil penalties for FDCA violations are legal in nature and do not fall under the public-rights exception that would permit agency adjudication without a jury. As a result, the Fifth Circuit granted the petition and vacated the agency’s decision. View "Texas Tobacco Barn v. HHS" on Justia Law

The defendant, a seventy-year-old man with a long history of alcohol use, was stopped by law enforcement after driving erratically and making multiple traffic violations. He was observed to be impaired, failed a field sobriety test, and later refused breath and blood tests, leading to a warrant for a blood draw that revealed a blood alcohol content over three times the legal limit. Investigation revealed he was driving with a suspended license and had three prior DUI convictions. He was charged with felony DUI (fourth or subsequent offense) and driving while suspended, but the latter charge was dismissed in exchange for his guilty plea to the DUI charge.The Montana Sixteenth Judicial District Court sentenced him to thirteen months with the Department of Corrections, recommended placement in an alcohol treatment program, and imposed a consecutive four-year suspended sentence. The court also imposed the statutory minimum fine of $5,000 but suspended half of it due to the defendant’s financial circumstances. The defendant appealed the imposition of the fine, arguing that the statute mandating the fine was unconstitutional based on recent case law. He maintained that the fine should not have been imposed without proper consideration of his ability to pay.The Supreme Court of the State of Montana held that the defendant did not waive his right to appellate review of the fine by agreeing to it in the plea agreement, as subsequent case law developments questioned the constitutionality of the statute. The Court reaffirmed that the sentencing court must impose the mandatory fine under the statute, then determine the defendant’s ability to pay, and may suspend any portion of the fine accordingly. The Supreme Court affirmed the imposition of the $5,000 fine but vacated the portion of the judgment relating to the fine and remanded to the District Court for explicit findings on the defendant’s ability to pay before determining how much of the fine should be suspended. View "State v. Hagberg" on Justia Law

Police responded to a domestic violence call involving the defendant after his girlfriend reported he had a firearm. Officers later found a purple handgun along the route the defendant had taken, and DNA evidence linked the gun to him. He was charged with felony domestic violence, misdemeanor unlawful carrying of a handgun, and felony unlawful carrying of a handgun by a felon with a prior conviction within the past fifteen years. The charging documents listed his two previous Texas felony convictions—one for Felon in Possession of a Weapon in 2014 and another for Aggravated Assault–Family Member in 2017—as the basis for the firearm charges.The Tippecanoe Superior Court dismissed both handgun-related charges, finding that the charging information was not sufficiently specific, did not constitute an offense, and that the statute used to enhance his charge was unconstitutionally vague under both federal and state constitutions. The trial court referenced an unrelated but identical dismissal for another defendant and issued a final judgment, allowing the State to appeal directly.The Indiana Supreme Court reviewed the case under its mandatory jurisdiction following a trial court finding of unconstitutionality. The court held that the charging information for both the misdemeanor and felony handgun counts was sufficiently certain and constituted an offense under Indiana law, as it included the necessary elements and identified the prior convictions. The court further held that the trial court had misapplied the relevant statute and that the enhancement to a felony did not require the prior out-of-state conviction to be substantially similar to an Indiana offense, only that it was a felony within fifteen years. The Indiana Supreme Court reversed the trial court’s dismissal of both handgun charges and remanded for further proceedings. View "State v. Jones" on Justia Law