Justia Constitutional Law Opinion Summaries

Texas law allows certain students, including those who are not lawfully present in the United States, to qualify for in-state tuition rates at public colleges if they meet residency requirements. The Texas Education Code provisions in question—sections 54.051(m) and 54.052(a)—permit illegal aliens who establish residency in Texas to pay discounted tuition, while out-of-state U.S. citizens must pay higher rates. The United States brought suit against Texas, alleging that these provisions violate federal law, specifically 8 U.S.C. § 1623(a), which bars states from granting postsecondary education benefits to illegal aliens based on residency unless all U.S. citizens and nationals are eligible for the same benefit regardless of residency.The United States District Court for the Northern District of Texas approved a consent judgment permanently enjoining Texas from enforcing the challenged provisions. After judgment, advocacy groups, a community college, and a student moved to intervene and sought to vacate or alter the judgment, arguing the provisions were not preempted by federal law. The district court denied intervention, reasoning it was legally futile because 8 U.S.C. § 1623(a) expressly preempts the Texas statutes.The United States Court of Appeals for the Fifth Circuit reviewed the denial de novo and affirmed. The court held that intervention was futile because federal law expressly preempts the Texas provisions, barring states from conferring in-state tuition benefits to illegal aliens based on residency unless all U.S. citizens and nationals may receive the same benefit without regard to residency. The court also dismissed the remaining claims for lack of appellate jurisdiction, as the movants were not parties to the case and therefore had no right to appeal the consent judgment. View "USA v. Texas" on Justia Law

A man was investigated after Google and Yahoo flagged several of his email accounts for sending and storing what appeared to be child pornography. Both companies identified the user through information like a shared recovery phone number, birthdate, and selfies associated with the accounts. Yahoo manually reviewed and confirmed the images as child pornography before reporting them to the National Center for Missing and Exploited Children (NCMEC). Google used both human review and a hash-value matching protocol, whereby a file’s unique digital fingerprint was compared against a database of previously identified illegal images. One of the files in the defendant’s account matched the hash of a known child pornography image. Law enforcement, after receiving tips from NCMEC, conducted warrantless searches and confirmed the illicit nature of the files, leading to search warrants for the defendant’s residence and devices, which yielded more incriminating evidence.The United States District Court for the Middle District of Florida denied the defendant’s motions to suppress the evidence (arguing a Fourth Amendment violation), to dismiss one of the charges on double jeopardy grounds, and to exclude certain evidence. The court also rejected his arguments concerning the admissibility of defense evidence, the sufficiency of the evidence, and the jury instructions. The defendant was convicted by a jury on both distribution and possession charges and given an enhanced sentence based on a finding of a pattern of activity involving abuse or exploitation. His subsequent motions for psychological evaluation and sentencing continuance were also denied.On appeal, the United States Court of Appeals for the Eleventh Circuit held that Google’s use of hash-value matching constituted a valid private search under the Fourth Amendment, so the government’s warrantless review did not violate the defendant’s rights. The court also held that possession and distribution of child pornography are separate offenses for double jeopardy purposes. The appellate court affirmed all district court decisions except for the application of a pattern-of-activity sentencing enhancement, which it found improper; it vacated the sentence and remanded for resentencing. View "USA v. Brillhart" on Justia Law

In response to a mass shooting in Illinois, the state enacted the Protect Illinois Communities Act, which criminalized the manufacture, sale, and possession of assault weapons and large-capacity magazines, with a grandfather clause allowing current legal owners to retain these items if they completed a registration process. Plaintiffs, including individuals and organizations, challenged the Act in federal court, arguing it violated the Second Amendment. The district court for the Southern District of Illinois consolidated four related cases and, after a bench trial, found that much of the Act violated the Second Amendment, concluding that its main provisions were not severable and enjoining the enforcement of the entire Act.Prior to this, at the preliminary injunction stage, the plaintiffs had received relief, but similar challenges in the Northern District of Illinois had been denied. The Seventh Circuit consolidated appeals from all these cases and previously held in Bevis v. City of Naperville that the plaintiffs were unlikely to prevail on the merits under the Supreme Court’s framework from New York State Rifle & Pistol Association v. Bruen. After further factual development and trial, the district court entered a permanent injunction against the Act, which the defendants appealed.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo on constitutional grounds. The court held that the Act’s restrictions on AR-15 rifles and thirty-round magazines are consistent with the nation’s historical tradition of firearms regulation. The court reasoned that legislatures have long imposed restrictions on particularly dangerous weapons, and Illinois’s law fits within this tradition. The court also held that the registration requirement was constitutional. The Seventh Circuit reversed the district court’s judgment and ordered the entry of judgment for the defendants, upholding the Act’s central restrictions. View "Barnett v Raoul" on Justia Law

In this case, federal drug enforcement agents received information suggesting that the defendant was involved in the distribution of large quantities of narcotics in Indiana. Following surveillance and a traffic stop that yielded evidence of drug activity, officers became concerned that the defendant was aware of their investigation. They installed a camera on a utility pole across the street from the defendant’s leased auto-repair shop without first obtaining a warrant. The property was surrounded by a six-foot fence, but it had significant gaps, including a thirty-foot-wide opening allowing vehicle and pedestrian access. The pole camera recorded activities on the property for approximately two weeks, capturing movements consistent with drug trafficking. Subsequent searches, supported by warrants, resulted in significant seizures of narcotics, firearms, and cash.The United States District Court for the Southern District of Indiana denied the defendant’s motion to suppress evidence obtained from the pole camera. The court held that the fence did not create a reasonable expectation of privacy in the observed activities because the gaps allowed visibility from the street. The court also found that the pole camera’s use was not a search requiring a warrant under prevailing precedent, and concluded that even without the camera footage, there was probable cause to support the search warrants. The court determined that, if necessary, the good-faith exception to the exclusionary rule would apply.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the use of the pole camera did not violate the Fourth Amendment. The court reasoned that the camera captured activities observable to passersby through the substantial gap in the fence, the technology was in common public use, and the officers were lawfully present. The court also emphasized that commercial properties receive less Fourth Amendment protection than residences. View "USA v Kendrick" on Justia Law

Jason Thomson was transported to a hospital in Green Bay, Wisconsin after suffering a seizure, where he later became agitated and aggressive toward hospital staff. Officers from the Green Bay Police Department responded, restrained Thomson—who repeatedly complained that he could not breathe—and placed him in a WRAP restraint device. Officers monitored his breathing and obtained a medical clearance from hospital staff before transporting him to jail. During transport and upon arrival at the jail, Thomson continued to state he could not breathe. At the jail, medical staff determined he could not be admitted and needed further hospital evaluation. Shortly after, Thomson suffered a cardiac arrhythmia and died.The Estate of Jason Thomson filed suit in the United States District Court for the Eastern District of Wisconsin, alleging that the officers used excessive force and failed to provide adequate medical care in violation of the Fourth Amendment, and asserting a failure-to-train claim against the City of Green Bay under Monell v. Department of Social Services of the City of New York. The district court granted summary judgment to the officers, the city, and Brown County, finding that the officers’ actions were objectively reasonable, that they did not violate Thomson’s rights, and that they were entitled to qualified immunity. The claims against Brown County and its officers, as well as a claim against a nurse, were subsequently resolved or dismissed.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The court held that no reasonable jury could find that the officers violated Thomson’s constitutional rights regarding medical care or excessive force. The court further held that the officers were entitled to qualified immunity, and, because no underlying constitutional violation was established, the Monell claim against the city also failed. The Seventh Circuit affirmed the judgment of the district court. View "Estate of Thomson v. Behn" on Justia Law

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses.At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held.At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

After threatening his ex-wife and her nephew with what appeared to be a firearm while intoxicated, an individual left his home and fell asleep at a neighbor’s house. Police were alerted, and, believing him to be inside and armed, surrounded the residence with S.W.A.T. teams and other tactical units. Negotiators eventually reached him by phone, during which he threatened self-harm and was reported to have threatened the officers, though he denied threatening the officers directly. When he exited the house, police fired non-lethal projectiles after he refused commands to come off the porch, seriously injuring his arm. After briefly retreating indoors, he reemerged and was shot three more times with similar ammunition when he acted aggressively and shouted threats at the officers.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the officers and the City, holding that the plaintiff failed to show the police violated clearly established constitutional rights under the Fourth Amendment. The district court distinguished the facts of this case from prior circuit precedent, including Phillips v. Community Insurance Corp., and found that the officers’ actions did not clearly contravene established law.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment ruling de novo. The appellate court held that qualified immunity shielded the officers because no binding precedent placed the unconstitutionality of their specific actions beyond debate, given the circumstances—namely, threats involving firearms and knives and the plaintiff’s aggressive behavior. The court also noted that the plaintiff failed to articulate a viable claim against the City of Elgin. The Seventh Circuit therefore affirmed the district court’s grant of summary judgment for all defendants. View "Davis v. City of Elgin, Illinois" on Justia Law

A woman was indicted on eleven counts of endangering children, each based on distinct disciplinary acts she committed against her minor stepson over several years. The indictment’s counts were nearly identical in charging language, but a bill of particulars provided by the prosecution detailed the specific conduct underlying each count. At trial, multiple witnesses, including the alleged victim and family members, described separate incidents of abusive discipline. The prosecution correlated each incident to a specific count, and both parties addressed the connections between acts and counts in their closing arguments. During jury deliberations, the jury twice asked the judge which punishments corresponded to which counts; the judge directed them to rely on the instructions and evidence. The jury found the defendant guilty on four counts and acquitted her on the others.Following these verdicts, the defendant appealed to the First District Court of Appeals, arguing that the failure of the trial court to specify which act matched each count in the jury instructions and verdict forms was plain error, violating her due-process and double-jeopardy rights. The First District agreed, reversed the convictions, and barred retrial.The Supreme Court of Ohio reviewed the case to determine whether, in prosecutions involving multiple identical counts of the same offense, the State must present separate evidence for each count and whether the jury instructions and verdict forms must specify the underlying conduct for each. The Supreme Court of Ohio held that when the State presents evidence of discernible facts corresponding to each count, and the proceedings allow the jury to differentiate among the counts, due-process and double-jeopardy concerns are not implicated. The Court found the instructions, verdict forms, and judge’s responses legally sufficient and determined that the prosecution had provided enough evidence to distinguish the counts. The Supreme Court of Ohio reversed the First District’s judgment and remanded for consideration of the defendant’s remaining appellate claims. View "State v. Rodriguez" on Justia Law

The case involved a defendant who, at age 18, ingested a large amount of LSD with a friend, AC, at her home. After taking the drug, the defendant removed his pants and underwear, made statements suggesting sexual intent, and groped AC. AC resisted and escaped, seeking help from her mother. The defendant then exhibited erratic behavior, fled into the night naked from the waist down, and was later found by police, who described him as hallucinating and confused. He was taken to a hospital, where, about an hour after being found, he was read his Miranda rights by a sheriff’s deputy. The defendant then made an incriminating statement, “I am a rapist and I am fucked,” during the ensuing interrogation.The Grand Traverse Circuit Court denied the defendant’s motion to suppress the statement, concluding he had made a valid waiver of his Miranda rights. After a jury trial, the defendant was convicted of assault with intent to commit criminal sexual conduct involving penetration. His motions for a new trial or an evidentiary hearing on ineffective assistance of counsel were denied. The Michigan Court of Appeals affirmed the conviction, finding any error in admitting the statement harmless because the victim’s testimony was sufficient for conviction.The Michigan Supreme Court reviewed the case and held that the defendant’s Miranda waiver was not knowing and intelligent, considering the totality of the circumstances, including his age, lack of law enforcement experience, exhaustion, and ongoing effects of LSD. The Court further held that the erroneous admission of the defendant’s statement was not harmless beyond a reasonable doubt, as it was highly prejudicial evidence of intent. The Supreme Court reversed the judgment of the Court of Appeals, vacated the conviction, and remanded for further proceedings. View "People Of Michigan v. Soriano" on Justia Law

In 1981, Dennis Sochor murdered Patricia Gifford after she refused his sexual advances; her body was never recovered. Sochor, who had fled the state after seeing himself on television, was apprehended in Georgia five years later and confessed multiple times to the crime. At trial, the jury found him guilty of kidnapping and first-degree murder, recommending a death sentence by a 10-2 vote. The trial court imposed the death penalty, finding four aggravating factors and no mitigating circumstances.On direct appeal, the Supreme Court of Florida affirmed Sochor’s conviction and sentence but was later instructed by the United States Supreme Court to conduct a harmless error analysis regarding one aggravator. After doing so, the Florida court again affirmed. Sochor's conviction and sentence became final in 1993. Since then, he has pursued numerous postconviction challenges in both state and federal courts, all unsuccessful. After the Governor signed a death warrant in June 2026, Sochor filed a sixth successive postconviction motion in the Circuit Court for Broward County, raising two claims: a Brady/Giglio violation concerning a 2022 letter to his brother, and a facial challenge to Florida’s lethal injection protocol. The circuit court summarily denied both claims as untimely, procedurally barred, and without merit.The Supreme Court of Florida reviewed the summary denial de novo and affirmed the circuit court’s ruling. The court held that Sochor’s method-of-execution claim was untimely because the evidence on which it relied had been discoverable since at least 2017, and that the claim was meritless because similar challenges to Florida’s lethal injection protocol had repeatedly been rejected. The court also denied Sochor’s motion for a stay of execution and declined to hold oral argument or entertain a motion for rehearing. View "Sochor v. State" on Justia Law