Justia Constitutional Law Opinion Summaries

Three individuals, each having entered the United States unlawfully more than a decade ago, were detained by federal immigration authorities after routine traffic stops in Texas. None had criminal histories, and each was a long-term resident and father of U.S. citizen children. They petitioned for cancellation of removal under 8 U.S.C. § 1229b(b)(1), claiming exceptional hardship to their U.S. citizen children if removed. After being detained without bond under 8 U.S.C. § 1225(b)(2)(A), they filed habeas corpus petitions, asserting their detention violated the Fifth Amendment’s Due Process Clause.The United States District Court for the Western District of Texas reviewed each petition, applying the procedural due process framework from Mathews v. Eldridge. The district courts found the mandatory detention regime unconstitutional as applied to these petitioners, ordered their immediate release, and required that any future detention must be preceded by a hearing to determine dangerousness or risk of flight. The government appealed these rulings, and the United States Court of Appeals for the Fifth Circuit consolidated the cases.The Fifth Circuit examined precedent, including Zadvydas v. Davis, Demore v. Kim, and Department of Homeland Security v. Thuraissigiam, and concluded that physical presence and long-term residence within the United States entitles aliens to due process protections. The court held that mandatory, indefinite detention of noncriminal, long-term resident aliens under § 1225(b)(2)(A) without a bond hearing violates the Fifth Amendment. The government must provide a bond hearing within ninety days of detention to determine if continued detention is justified by individualized findings of dangerousness or flight risk. The court affirmed the district courts’ grants of habeas corpus and clarified the scope of its decision to similar aliens detained under § 1225(b)(2)(A). View "Sosnava Rodriguez v. Ortega" on Justia Law

A Maine Catholic school, the Roman Catholic Diocese that operates it, and parents seeking to send their children there challenged several antidiscrimination provisions in Maine’s Human Rights Act (MHRA). The MHRA applies to schools receiving public tuition assistance and prohibits discrimination based on religion, sexual orientation, and gender identity. St. Dominic Academy, not currently receiving tuition assistance but eligible to do so, argued that these rules would require them to change admissions and employment policies central to their religious mission, including prioritizing Catholic students and requiring conformity with Catholic teachings. The school also objected to policies on gender identity that would compel the school to use students’ preferred pronouns and permit dress consistent with gender identity, potentially over parental objections.The United States District Court for the District of Maine denied St. Dominic’s request for a preliminary injunction, finding the school’s employment practices protected by MHRA carveouts and determining St. Dominic had not shown a likelihood of success on its other claims. The court also denied similar relief in a companion case brought by another religious school, and entered final judgment for the state officials.Reviewing the appeal, the United States Court of Appeals for the First Circuit affirmed in part and reversed in part. The court affirmed that St. Dominic lacked standing to challenge the employment rule, and that the challenges to the religious nondiscrimination and sexual orientation/gender identity rules were unlikely to succeed: these rules are neutral, generally applicable, and rationally related to legitimate state interests. However, the court reversed as to the “Religious Expression Rule,” finding it facially nonneutral and likely unconstitutional under the Free Exercise Clause. The First Circuit ordered entry of a preliminary injunction against enforcement of this rule as applied to St. Dominic. The parental-rights claim was deemed moot and remanded for dismissal. View "St. Dominic Academy v. Makin" on Justia Law

A Christian church in Maine operates a private K–12 school that adheres closely to its religious beliefs, including requiring students and staff to conform to a statement of faith and specific codes of conduct and dress. The school is willing to admit students of any background if their families support its religious philosophy, but it maintains policies that exclude students who are openly gay or transgender and requires employees to be co-religionists. The school sought to participate in Maine’s tuition-assistance program, which allows public funds for private education in certain circumstances, but did not apply because of state nondiscrimination laws it believed would conflict with its religious practices.The United States District Court for the District of Maine denied the school’s motion for a permanent injunction against several provisions of the Maine Human Rights Act (MHRA), finding either no case or controversy or no constitutional violation. The case reached the United States Court of Appeals for the First Circuit after the parties stipulated to final judgment based on the preliminary injunction record, reserving all appellate rights.The United States Court of Appeals for the First Circuit reviewed whether the MHRA’s rules on employment, religious expression, religious nondiscrimination, and sexual orientation/gender identity nondiscrimination violate the First Amendment as applied to the school. The court held there was no case or controversy regarding the employment rule due to existing carveouts. It affirmed the district court’s rejection of the school’s challenges to the religious nondiscrimination and sexual orientation/gender identity rules, finding no constitutional violation. However, the court determined that the religious expression rule violates the school’s free-exercise rights and must be enjoined as applied to the school. The judgment was affirmed in part and reversed in part, and the case was remanded for entry of a permanent injunction against enforcement of the religious expression rule. View "Crosspoint Church v. Makin" on Justia Law

After a late-night police pursuit in Makaha, a white Honda being followed by several Honolulu Police Department officers crashed, causing severe injuries to its young occupants. Officer Joshua Nahulu was alleged to have driven the lead pursuit vehicle, with officers Erik Smith, Jake Ryan Bartolome, and Robert Gus Lewis III following. Witness accounts conflicted on whether police vehicles made physical contact with the Honda. However, an expert found no evidence of such contact. None of the officers stopped to render aid after the crash, and they only returned after other emergency responders had arrived. Nahulu was charged under Hawaiʻi’s “fled scene” statute, which requires a driver “involved in a collision” resulting in serious injury or death to stop and render aid. His co-defendants were charged with hindering prosecution and conspiracy.The Circuit Court of the First Circuit denied the defendants’ motions to dismiss, finding the statute’s language—specifically, “involved in a collision”—was not unconstitutionally vague and that the defendants had sufficient notice of the charges. The court ordered the State to clarify, through a bill of particulars, whether it alleged physical contact between Nahulu’s vehicle and the Honda; the State responded that it did not rely on such a theory.On appeal, the Supreme Court of the State of Hawaiʻi held that Nahulu could only challenge the statute as vague as applied to his conduct, not on its face, since the law does not implicate constitutional rights such as free speech. The court further held that “involved in a collision” is not unconstitutionally vague as applied to Nahulu and that the combination of the charging instrument and the bill of particulars provided sufficient notice of the nature and cause of the accusation. The Supreme Court affirmed the circuit court’s denial of the motions to dismiss. View "State v. Nahulu" on Justia Law

The case centers on a defendant charged with multiple crimes stemming from a fatal gang-related shooting in Watts, Los Angeles. Two eyewitnesses, one from inside the victim’s car and another from a nearby house, identified the defendant as the shooter or as fleeing the scene. Their identification was primarily based on a photo lineup and their testimony at trial. The first trial ended in a hung jury, but during the retrial, both witnesses added new details, claiming to have told police about key identifying features or sightings soon after the shooting. These statements were contradicted by police interview transcripts, which were not presented at trial.Following the retrial, the defendant was convicted of murder, attempted murder, shooting at an occupied vehicle, and possession of a firearm by a felon. On direct appeal, one attempted murder conviction was reversed, but the rest of the judgment was affirmed by the California Court of Appeal. The defendant filed a habeas corpus petition, alleging that the prosecution allowed false testimony and that his trial counsel was ineffective for failing to impeach the witnesses. The Los Angeles County Superior Court denied the petition after an evidentiary hearing, finding the witnesses’ statements to be merely inconsistent, not false. The California Supreme Court then ordered the Court of Appeal to reconsider the habeas petition.The California Court of Appeal, Second Appellate District, reviewed the petition and found that the prosecution failed its constitutional duty to correct false testimony from its witnesses, and defense counsel’s lack of preparation contributed to the use of false evidence. Applying the materiality standard from Napue v. Illinois and Glossip v. Oklahoma, the court held that the People did not prove beyond a reasonable doubt that the false testimony did not contribute to the conviction. The court granted the writ of habeas corpus, vacated the conviction, and remanded the case for further proceedings. View "In re Melson" on Justia Law

After a robbery at a Chinese restaurant owner’s home in South Carolina, three masked men assaulted the family and stole their earnings. The victims could not identify the attackers, and no forensic evidence was left behind. Weeks later, a tip led investigators to three suspects, including K.C. Langford, who was arrested and indicted along with two co-defendants. Langford’s trial was delayed for nearly two years, partly due to difficulties in securing an interpreter for the victims and because one co-defendant, Alvin, initially refused to testify after being pressured by Langford and another defendant. The trial eventually proceeded, with Alvin testifying against Langford. Langford was convicted of criminal conspiracy, armed robbery, first-degree burglary, and kidnapping.After conviction, Langford appealed to the South Carolina Supreme Court, which affirmed his convictions. The court found that although the prosecutor’s control over the trial docket violated the state constitution, Langford suffered no prejudice from it. Applying the Barker v. Wingo framework, the court determined the nearly two-year delay did not violate Langford’s Sixth Amendment right to a speedy trial, considering the reasons for the delay and lack of prejudice to Langford’s defense. Langford’s postconviction relief application in the Court of Common Pleas was denied, as the court found no ineffective assistance of counsel regarding a hearsay issue in the trial. The South Carolina Court of Appeals denied certiorari. Langford’s co-defendant, Bryan, received postconviction relief in a separate proceeding.Langford then sought federal habeas corpus relief in the United States District Court for the District of South Carolina, which granted the writ on claims of speedy trial violation and ineffective assistance of counsel. The United States Court of Appeals for the Fourth Circuit reversed, holding that the South Carolina courts’ decisions were not unreasonable applications of clearly established federal law nor based on unreasonable factual determinations. The Fourth Circuit ordered reversal of the district court’s grant of habeas corpus. View "Langford v. Stonebreaker" on Justia Law

In 2009, Jonathan Rose was involuntarily committed to a mental institution in Indiana due to a psychiatric disorder, though the specific diagnosis and its severity were not detailed in the record. He was released in early 2010 and has not been recommitted since. In 2022, Rose successfully purchased multiple firearms, though he was denied others after background checks revealed his prior commitment. In 2023, he was indicted under federal law for possessing firearms as a person previously committed to a mental institution and for making false statements to firearms dealers by denying his commitment history.The United States District Court for the Northern District of Indiana reviewed Rose’s case and dismissed the counts related to possession of firearms by a previously committed person under 18 U.S.C. §922(g)(4). The district court reasoned that this statute, as applied to someone no longer suffering from mental illness, was inconsistent with the Second Amendment, particularly in light of recent Supreme Court decisions emphasizing individualized assessments of current danger rather than permanent disabilities based on past conditions.The United States Court of Appeals for the Seventh Circuit considered the government’s appeal. The court determined that the district court should not have dismissed the indictment without an evidentiary hearing to assess Rose’s current mental health and dangerousness. The Seventh Circuit held that, after recent Supreme Court decisions, the constitutionality of §922(g)(4) as applied depends on whether the defendant currently poses a credible threat to the safety of others. Because the record lacked evidence concerning Rose’s present mental condition, the appellate court vacated the district court’s order and remanded for further proceedings to develop the necessary facts. View "USA v Rose" on Justia Law

A regional air quality agency responsible for the South Coast Air Basin, an area with some of the nation’s worst ozone pollution, amended its regulations to phase in zero nitrous oxide (NOx) emissions standards for certain appliances, such as water heaters, boilers, and process heaters. The agency determined that only widespread adoption of zero emissions standards across stationary sources could bring the region into compliance with federal ozone requirements imposed by the Clean Air Act (CAA). The rule’s implementation was staggered over several years, with the goal of achieving significant NOx reductions. Plaintiffs, including manufacturers and industry groups, challenged this rule, arguing that it was preempted by the federal Energy Policy and Conservation Act (EPCA), which sets national energy efficiency standards for consumer products.The United States District Court for the Central District of California considered the plaintiffs’ facial preemption challenge. The district court granted summary judgment to the air quality agency, finding that the rule did not concern the “energy use” of appliances as defined by EPCA, but instead addressed air pollution and health risks. The court concluded that the rule did not trigger EPCA’s preemption provisions.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the case de novo. The Ninth Circuit affirmed the district court’s decision, holding that EPCA does not preempt the agency’s amended rule because nothing in EPCA’s text, structure, or history indicates Congressional intent to interfere with state and local efforts to achieve federal air quality standards under the CAA. The court also found that plaintiffs had not shown any EPCA language preempting CAA-based emissions regulations, and distinguished its earlier decision in California Restaurant Association v. City of Berkeley as inapplicable here. Finally, the court held that the facial challenge failed because the rule applies to some products not covered by EPCA, and thus was not unconstitutional in every application. The judgment for the agency was affirmed. View "RINNAI AMERICA CORP. V. SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT" on Justia Law

Jquan Leearthur McInnis, then a juvenile, shot and killed Gustav Christianson and an infant, J.R., by firing seven shots into a car in downtown Minneapolis. Evidence gathered by investigators included statements made by McInnis to associates and forensic evidence showing the sequence of shots. After being apprehended and advised of his Miranda rights, McInnis initially denied involvement but eventually confessed to the shootings after invoking his right to remain silent. He maintained that he did not intend to kill Christianson and was unaware of the infant’s presence.The case was tried in a Minnesota state court, where McInnis moved to suppress his confession, arguing it was obtained after he had invoked his Fifth Amendment rights. The trial court denied the motion, concluding that McInnis had not unequivocally invoked his right to remain silent. The trial proceeded on stipulated evidence, including the confession, and McInnis was convicted of two counts of first-degree murder and sentenced to two consecutive life terms with the possibility of parole. On appeal, the Minnesota Supreme Court agreed that the confession should have been suppressed but determined that its admission was harmless beyond a reasonable doubt, given the other overwhelming evidence of guilt.McInnis then sought a writ of habeas corpus from the United States District Court for the District of Minnesota, arguing that the Minnesota Supreme Court unreasonably applied federal law on harmless error. The district court denied relief but granted a certificate of appealability on the harmless error issue. On appeal, the United States Court of Appeals for the Eighth Circuit held that McInnis failed to show that the Minnesota Supreme Court’s harmless error determination was contrary to or an unreasonable application of clearly established federal law. The Eighth Circuit affirmed the district court’s denial of the habeas petition. View "McInnis v. Bolin" on Justia Law

Derek Anderson sought to incorporate a new town called West Hills in Summit County, Utah, along Highway 248. To comply with Utah’s municipal incorporation code, Anderson followed a process involving proposals, notices, hearings, and multiple boundary adjustments. The incorporation procedure allows certain landowners, defined as "specified landowners" based on property size or value, to request exclusion from the proposed municipality during two specific windows: after initial notice and after the first public hearing. Anderson modified the proposed boundaries several times, and in doing so added some landowners after both opt-out windows had closed, depriving them of the statutory opportunity to request exclusion.Summit County’s Third District Court reviewed the case after these landowners, including Jennifer McCaffrey and others, sued to stop the incorporation election. They argued that the incorporation code violated the Uniform Operation of Laws Clause of the Utah Constitution by allowing some landowners to request exclusion while denying this right to others who were added later. The district court applied rational basis review and found that the code’s classification failed this standard, reasoning that the timing for boundary locking was arbitrary and allowed sponsors to manipulate which landowners had exclusion rights. The court granted summary judgment to the landowners and enjoined the Lieutenant Governor from certifying the incorporation petition.The Supreme Court of the State of Utah reviewed the appeal. The Court held that, under rational basis review, the legislative scheme for exclusion rights was constitutional. It found that the statutory cutoff for opt-outs was a reasonable means to ensure finality and prevent endless boundary modifications, and that the classification had a rational connection to legitimate legislative objectives. The Court reversed the district court’s ruling and reinstated the Lieutenant Governor’s certification of the incorporation petition for the 2026 general election. View "McCaffrey v. Anderson" on Justia Law