Justia Constitutional Law Opinion Summaries

Richard Knight was convicted of the first-degree murders of Odessia Stephens and her four-year-old daughter, Hanessia Mullings, with evidence including Knight’s presence at the scene, forensic findings tying him to the crime, and his confession to a fellow inmate. After a jury unanimously recommended the death penalty for both murders, the trial court imposed two death sentences, finding multiple aggravating factors and limited nonstatutory mitigation.On direct appeal, the Supreme Court of Florida affirmed Knight’s convictions and sentences. Subsequent postconviction and habeas proceedings in both state and federal courts were unsuccessful. After the Governor signed Knight’s death warrant, Knight filed a successive postconviction motion in the Circuit Court for Broward County, raising three claims: that unidentified fingerprint evidence constituted newly discovered evidence, that Florida’s lethal injection protocol was unconstitutional, and that the expedited death warrant process deprived him of due process. The circuit court summarily denied all claims and related motions.The Supreme Court of Florida reviewed the summary denial de novo and affirmed. The court held that the unidentified fingerprint claim was untimely, procedurally barred, and without merit, as the evidence was known at trial and did not undermine the case against Knight. The lethal injection claim was also found untimely, procedurally barred, and legally insufficient, as Knight failed to show a substantial risk of harm or propose a feasible alternative method. Lastly, the court rejected the due process claim, finding that Knight received adequate notice and opportunity to be heard. The court denied the request for a stay of execution, and ordered that no oral argument or rehearing would be permitted, with the mandate to issue immediately. View "Knight v. State" on Justia Law

Maryland enacted legislation regulating how retail electricity suppliers may market “green power” to consumers, seeking to address concerns that consumers were misled by claims about renewable energy. The statute prohibits suppliers from using terms such as “clean,” “green,” or “100% renewable” unless at least 51% of the energy is backed by renewable energy credits (RECs) from within a specific regional grid (the PJM region). Additionally, suppliers are required to include disclosures explaining the nature of RECs and their relationship to renewable electricity, with the exact disclosure language later specified by the Maryland Public Service Commission (PSC).Retail Energy Advancement League and Green Mountain Energy Company brought a facial First Amendment challenge against these provisions and sought a preliminary injunction in the United States District Court for the District of Maryland. The district court denied the injunction, applying intermediate scrutiny to the speech restriction and concluding that the plaintiffs were unlikely to prevail on the merits. The court also found that the statute’s disclosure requirements likely survived constitutional review.On appeal, the United States Court of Appeals for the Fourth Circuit found that the plaintiffs demonstrated a likelihood of success in showing the speech restriction was unconstitutional even under intermediate scrutiny, because the restriction did not materially advance Maryland’s asserted interest in preventing consumer deception and was not adequately tailored. The Fourth Circuit reversed the district court’s denial of a preliminary injunction as to the speech restriction and ordered an injunction against enforcement of that provision. However, regarding the compelled disclosure requirement, the Fourth Circuit remanded the case for the district court to review the constitutionality of the new PSC-promulgated disclosure language in the first instance. View "Retail Energy Advancement League v. Brown" on Justia Law

A private company operating a hotel sought the renewal of a one-year, revocable state land permit for property fronting its hotel. A member of the public, who had long used the area for recreation, objected to the permit's renewal, particularly the practice of presetting hotel lounge chairs, which he argued deterred public use. He requested a formal contested case hearing on the permit renewal, asserting a property interest in the recreational and environmental quality of the public land. The Board of Land and Natural Resources (BLNR) denied his request for such a hearing, instead allowing only written and oral testimony at a public meeting.The objector appealed to the Circuit Court of the First Circuit, which upheld the BLNR's denial, finding that he had been afforded due process through the public meeting process. On further appeal, the Intermediate Court of Appeals (ICA) reversed, holding that the appellant had a constitutionally protected interest in a clean and healthful environment and was entitled to a contested case hearing before the permit could be renewed. Because the permit had expired, the ICA remanded the case to the circuit court to determine what relief, if any, remained available. The ICA granted costs but denied the appellant’s request for attorney fees under the private attorney general (PAG) doctrine, reasoning that the requirements for such fees were unmet since the scope of relief was not yet determined.The Supreme Court of the State of Hawai‘i vacated the ICA’s denial of attorney fees. The court held that the PAG doctrine does not require the prevailing party to obtain final relief before becoming eligible for attorney fees. Determining that all three prongs of the PAG test were met, the court remanded the matter for the ICA to determine the reasonableness of the appellant’s attorney fees and whether the hotel company was liable for them. View "Ralston v. Board of Land and Natural Resources." on Justia Law

The defendant waited outside his estranged wife’s home late at night and, as she entered her car to leave for work, confronted and shot her eight times, causing her death. Immediately after the killing, he sent graphic text messages and explicit images to her family members, referencing the murder and making degrading statements about the victim. Police later found evidence at his residence, including a calendar marking the date as “judgment day.” He was indicted for first degree murder, and the prosecution sought the death penalty, alleging the crime was committed in an especially heinous, cruel, or depraved manner.At trial in the Superior Court in Maricopa County, the defense conceded the defendant killed his wife but argued there was no premeditation, requesting the jury consider lesser offenses. The jury convicted him of first degree murder. In the penalty phase, the jury found the aggravating factor of “especially heinous or depraved” and sentenced him to death. The defendant moved for a mistrial on various grounds, including alleged prosecutorial error, juror misconduct, and late disclosure of a prior conviction, but the trial court denied these motions and imposed the death sentence.The Supreme Court of the State of Arizona reviewed the case on direct appeal. The court held that the prosecutor committed some isolated errors, such as misstating the evidence and improperly suggesting the defense believed jurors were “bullies,” but found these errors neither individually nor cumulatively deprived the defendant of a fair trial. The court determined there was sufficient evidence to support the “especially heinous or depraved” aggravator, that the jury instructions were adequate, and that the trial court did not abuse its discretion in handling disclosure issues or juror misconduct. The court affirmed both the conviction and the imposition of the death sentence. View "STATE OF ARIZONA v MCCAULEY" on Justia Law

A group of members of the Texas House of Representatives left the state in August 2025 to prevent the House from reaching the two-thirds quorum required to conduct business. Their absence was intended to block the passage of redistricting legislation. After approximately two weeks, the absent members voluntarily returned, restoring the quorum and allowing the legislation to proceed. The Governor subsequently signed the redistricting bill into law, and the state began conducting elections under the new district lines.In response to the walkout, the Governor and the Attorney General filed petitions for writs of quo warranto with the Supreme Court of Texas, seeking to remove certain absent legislators from office. They argued that by intentionally leaving the state to prevent the House from functioning, those members had abandoned or forfeited their offices. The accused legislators, in turn, contended that quorum-breaking is a legitimate legislative tactic and does not constitute abandonment or forfeiture of office. While the House itself employed limited disciplinary measures during the walkout, including withholding financial resources from absent members, it did not expel any member or seek judicial intervention.The Supreme Court of Texas denied the petitions for writs of quo warranto. The Court held that the Texas Constitution assigns the power to compel the attendance of absent legislators and discipline members to each legislative house, not to the courts. The Court emphasized that political mechanisms provided by the Constitution were sufficient to address the situation and that judicial intervention was unwarranted. The Court declined to exercise discretionary jurisdiction over the petitions and did not resolve whether a judicial remedy might ever be available in similar circumstances. The petitions were denied. View "IN RE STATE OF TEXAS" on Justia Law

After the Texas Legislature enacted Senate Bill 8, which created a private civil enforcement mechanism for certain abortion restrictions, the Lilith Fund for Reproductive Equity’s deputy director made a sworn statement indicating the Fund had paid for abortions potentially in violation of that law. In response, Sadie Weldon filed a Rule 202 petition in Jack County seeking to depose the deputy director and obtain documents related to possible violations of the statute. While Weldon's petition was pending, the Lilith Fund initiated a lawsuit against Weldon, seeking a declaratory judgment that the statute was unconstitutional, as well as injunctive relief to prevent Weldon from pursuing related legal actions.The trial court denied Weldon’s Rule 202 petition, and Weldon subsequently filed a motion to dismiss the Lilith Fund’s suit under the Texas Citizens Participation Act (TCPA), which aims to quickly dispose of lawsuits that chill the exercise of free speech, association, or petition. The trial court did not rule on Weldon’s TCPA motion, resulting in its denial by operation of law. Weldon appealed, but the Court of Appeals for the Second District of Texas affirmed the denial, holding that the TCPA did not apply because the Fund’s suit was not “based on or in response to” Weldon’s Rule 202 petition.The Supreme Court of Texas reviewed the case and held that the TCPA does apply. The Court found that the Fund’s legal action was indeed “based on or in response to” Weldon’s exercise of her right to petition, as her Rule 202 petition was a protected activity under the statute and the Fund’s lawsuit sought relief directly connected to that petition. As a result, the Supreme Court of Texas reversed the judgment of the court of appeals and remanded the case for further proceedings under the remaining steps of the TCPA analysis. View "WELDON v. THE LILITH FUND FOR REPRODUCTIVE EQUITY" on Justia Law

A fatal traffic collision occurred when Joseph Feghhi, driving at nearly 130 miles per hour, rear-ended another vehicle, resulting in the death of Vanessa Arellano. Law enforcement officers at the scene observed signs of alcohol impairment in Feghhi and conducted field sobriety tests. Feghhi initially refused to submit to a chemical test but later expressed willingness to take a breath test. Officers obtained a search warrant for a blood sample, which was taken over three hours later and revealed a blood alcohol concentration of 0.14 percent. Feghhi was charged with multiple offenses, including murder, gross vehicular manslaughter, and driving under the influence causing injury.A magistrate found sufficient evidence to hold Feghhi to answer on all charges. Feghhi then moved in the Santa Clara County Superior Court to quash and traverse the search warrant and suppress the blood evidence, arguing that the officer’s affidavit omitted his willingness to take a breath test, thereby misleading the magistrate who issued the warrant. The prosecution opposed, contending that probable cause existed regardless of the alleged omission. The trial court granted Feghhi’s motion, concluding that the magistrate would not have issued the warrant had it been aware of Feghhi’s consent to a breath test, and suppressed the blood test evidence.The California Court of Appeal, Sixth Appellate District, reviewed the case after the prosecution sought a writ of mandate. The appellate court held that, even if the officer’s failure to include Feghhi’s willingness to take a breath test was a deliberate omission, correcting the affidavit would not have changed the probable cause analysis or rendered the warrant unreasonable under the Fourth Amendment. The court directed that a peremptory writ of mandate issue, ordering the trial court to vacate its order granting the motion to traverse and suppress, and to enter a new order denying the motion. View "People v. Super. Ct." on Justia Law

A law enforcement officer conducted a traffic stop of an individual suspected of participating in a series of armed robberies. During the stop, the suspect, D’Juantez Mitchell, did not comply with police orders and drove his vehicle into the officer and toward another officer. In response, the officer shot and killed Mitchell. Mitchell’s estate and children challenged the officer’s use of deadly force, alleging violations of constitutional rights and Kentucky law.The United States District Court for the Western District of Kentucky granted the officer qualified immunity on federal claims brought under 42 U.S.C. § 1983, concluding there was no violation of clearly established federal law. However, the district court denied the officer’s motion for summary judgment on the state-law claims, finding a genuine dispute as to whether the officer acted in subjective good faith, and thus denied Kentucky qualified official immunity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified official immunity under Kentucky law de novo. The appellate court held that the officer’s use of deadly force constituted a discretionary act under Kentucky law and that the plaintiffs failed to provide evidence sufficient to rebut the presumption that the officer acted in good faith. The court found that neither purported inconsistencies in the officer’s testimony nor affidavits concerning his general racial animus created a genuine issue of material fact regarding his subjective intent during the incident. The court emphasized that the video evidence showed the officer and another were in imminent danger when the vehicle moved, supporting the officer’s stated belief that deadly force was necessary.The Sixth Circuit reversed the district court’s denial of qualified official immunity, holding that the officer was entitled to immunity from the state-law claims. View "Mitchell v. Conrad" on Justia Law

The Wyoming legislature enacted the Steamboat Legacy Scholarship Act in 2025, creating an education savings account (ESA) program. This program allows parents of eligible Wyoming school-aged children to apply for up to $7,000 annually to fund education expenses outside the public school system. The ESAs are funded from a state general fund appropriation, not from local or school district taxes. Plaintiffs, including the Wyoming Education Association (WEA) and several individual parents, challenged the Act’s constitutionality, claiming it violated provisions of the Wyoming Constitution related to public education and state appropriations. The plaintiffs argued that the Act would harm their children, particularly those with disabilities, because private schools receiving ESA funds could deny admission or fail to provide needed services.The District Court of Laramie County granted a preliminary injunction, preventing implementation and funding of the ESA program while the lawsuit proceeded. The district court found that the plaintiffs were likely to succeed on the merits of their constitutional claims and that they would suffer irreparable injury if funds were distributed under the Act. The court reasoned that the Act likely violated constitutional limitations on appropriations for educational purposes to entities not under state control, and infringed upon the fundamental right to education by diverting funds from the public system.On appeal, the Supreme Court of Wyoming reviewed the district court’s decision for abuse of discretion. The Supreme Court held that the plaintiffs had not made a clear showing of possible irreparable, personal injury required for preliminary injunctive relief, as they did not intend to participate in the ESA program and their alleged harms were speculative. The court also questioned the district court’s legal analysis but did not decide the case on the merits. The Supreme Court of Wyoming reversed the preliminary injunction and remanded the case for further proceedings. View "Degenfelder v. Wyoming Education Association" on Justia Law

Marcus Roland Maye was convicted of robbery with a deadly weapon in May 2002 and received a mandatory life sentence under Florida’s Prison Releasee Reoffender (PRR) statute. He later filed a motion under Florida Rule of Criminal Procedure 3.800(a), arguing that the procedures of the PRR statute were unconstitutional. Specifically, he claimed that the statute allowed a judge, rather than a jury, to make findings that exposed him to a mandatory minimum sentence, in violation of the rules set out in Apprendi v. New Jersey and Alleyne v. United States.The State opposed Maye’s motion, contending that rule 3.800(a) was not the proper procedural mechanism to challenge a statute's constitutionality and that existing district court precedent foreclosed his claim. The circuit court, bound by precedent holding section 775.082(9) constitutional, denied the motion. On appeal, the Sixth District Court of Appeal affirmed the denial, citing the same precedent.Upon review, the Supreme Court of Florida approved the Sixth District’s result but based its decision on a different ground. The court held that claims of error under Apprendi and its progeny (such as Alleyne) are not cognizable under rule 3.800(a) because those claims are subject to harmless error review and do not constitute “illegal sentences” as contemplated by the rule. The court receded from its earlier decision in Plott v. State, which had allowed such claims to be raised under rule 3.800(a). Accordingly, the Supreme Court of Florida ruled that Maye’s Apprendi claim could not be raised in a rule 3.800(a) motion and affirmed the result below on that basis. View "Maye v. State of Florida" on Justia Law