Justia Constitutional Law Opinion Summaries

Six nonbinary individuals born in Puerto Rico sought to amend their birth certificates to reflect a nonbinary gender marker ("X"), arguing that the existing Application for Gender Change, which only allowed selection of "male" or "female," discriminated against them. Their request followed an earlier federal court decision (Arroyo González v. Rossello Nevares) that required Puerto Rico to allow transgender binary individuals to amend their birth certificates, but did not address nonbinary persons. After their request was denied by the Director of the Demographic Registry, the plaintiffs filed suit, alleging violations of their constitutional rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment and the First Amendment.The United States District Court for the District of Puerto Rico reviewed cross-motions for summary judgment. The district court granted summary judgment to the plaintiffs on their Equal Protection claim, finding that Puerto Rico’s Birth Certificate Policy created a facial classification between binary and nonbinary individuals. The court applied rational basis review and concluded that Puerto Rico’s stated interests—including separation of powers and maintaining the integrity of public records—did not justify the exclusion of a nonbinary option. It found no rational basis for the policy and inferred animosity towards nonbinary persons, ordering Puerto Rico to amend its Application for Gender Change to include an "X" gender marker.The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment order de novo. The appellate court concluded that Puerto Rico's Birth Certificate Policy is supported by a rational basis, specifically Puerto Rico’s legitimate interest in protecting privacy rights. Because the plaintiffs did not demonstrate that the policy infringes on their privacy rights or that privacy rights are not furthered by the policy, the court found a rational relationship between the challenged classification and the government’s legitimate goals. The First Circuit vacated the district court’s order and remanded for further proceedings. View "de la Fuente Diaz v. Gonzalez Colon" on Justia Law

A pickup truck driven by Lilly Laroque collided head-on with another vehicle on a Montana highway, resulting in serious injuries to Laroque and the death of the other driver, Delaney Doherty. At the crash scene, law enforcement found marijuana-related items in Laroque’s vehicle, and evidence suggested Laroque had been texting and using marijuana while driving shortly before the crash. While hospitalized after the accident, Sergeant Stoner of the Montana Highway Patrol requested a blood sample from Laroque to test for intoxicants, reading her the Montana Implied Consent Advisory. Laroque did not respond verbally to repeated requests for consent, and the officer directed medical staff to draw her blood, which later tested above the legal limit for THC.The Eighteenth Judicial District Court of Montana reviewed Laroque's motion to suppress the blood sample and toxicology report, considering arguments that the warrantless blood draw violated her constitutional protections against unreasonable searches and seizures. The State argued that Montana’s Implied Consent statute authorized the blood draw, relying on precedent from City of Great Falls v. Allderdice. The District Court found Laroque did not exhibit understanding or consent required by the Implied Consent Advisory, distinguishing her case from Allderdice. The court suppressed the evidence, finding no exception to the warrant requirement applied and declined to apply the good faith exception. The State appealed this suppression order.The Supreme Court of the State of Montana reviewed whether the District Court’s finding that Laroque did not consent was clearly erroneous. Applying the clear error standard, the Supreme Court found substantial evidence supported the District Court’s conclusion that Laroque did not consent to the warrantless blood draw. The Supreme Court affirmed the suppression of the blood sample and toxicology report, holding the District Court’s factual findings were not clearly erroneous and declining to address the State’s good faith doctrine argument, as it was not raised below. View "State v. Laroque" on Justia Law

A physician brought a lawsuit on behalf of the United States under the False Claims Act (FCA), alleging that her employer and associated healthcare entities knowingly submitted false diagnosis codes to Medicare in order to obtain inflated payments. The case proceeded for several years. In February 2024, the defendants sought judgment on the pleadings or dismissal, arguing that the FCA’s qui tam provisions—which allow private individuals (relators) to sue on behalf of the government—violated the Constitution’s Appointments Clause, Take Care Clause, and Vesting Clause.The United States District Court for the Middle District of Florida granted the defendants’ motion, concluding that the qui tam provisions violated the Appointments Clause. The district court reasoned that relators are “officers of the United States” because they exercise significant federal authority and occupy a continuing position established by law, but are not appointed by the President as required by Article II. The court dismissed the case, finding the relator lacked authority to proceed on behalf of the United States, and did not address the other constitutional arguments.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s constitutional analysis de novo. The Eleventh Circuit disagreed with the lower court’s conclusion, holding that relators under the FCA are not officers of the United States because they do not occupy a continuing position established by law. The court explained that relators’ roles are temporary, personal, and lack a continuing emolument or transferable duties. Therefore, the FCA’s qui tam provisions do not violate the Appointments Clause. The Eleventh Circuit vacated the district court’s dismissal and remanded the case for consideration of the remaining constitutional arguments. View "Zafirov v. Florida Medical Associates, LLC" on Justia Law

Sidney Campbell was convicted by a jury of second degree murder in 2003 after he and his brother shot and killed a 15-year-old boy following a confrontation related to a damaged bicycle rim. Witnesses testified that Campbell was one of the shooters, and the jury found he personally used and discharged a firearm during the offense. The jury was not instructed on felony murder or the natural and probable consequences doctrine, but was instructed on implied malice.Following his conviction, Campbell was sentenced to 35 years to life. The California Court of Appeal previously affirmed his conviction. In 2022, Campbell filed a petition for resentencing under Penal Code section 1172.6, arguing that recent statutory amendments and relevant case law might render him eligible for relief because his conviction could have rested on an imputed malice theory, particularly given ambiguities in the aiding and abetting instructions. The Los Angeles County Superior Court summarily denied the petition at the prima facie stage, finding Campbell ineligible for resentencing as a matter of law.The California Court of Appeal, Second Appellate District, Division Six, reviewed the trial court’s denial after the California Supreme Court directed reconsideration in light of People v. Lopez (2026) 19 Cal.5th 639, which clarified that the ability to raise instructional error on direct appeal does not categorically bar relief under section 1172.6. The appellate court independently reviewed the record and concluded that the jury instructions did not allow for conviction based on imputed malice and that it was not reasonably likely the jury relied on such a theory. Therefore, Campbell was found ineligible for resentencing as a matter of law. The order denying Campbell’s section 1172.6 petition was affirmed. View "People v. Campbell" on Justia Law

Federal agents intercepted a package containing three silencers shipped from China to Joseph Berger’s residence in Bethlehem, Pennsylvania. Upon searching the home with a warrant, agents discovered more than sixty firearms, including thirteen fully automatic guns (mostly AK-47 variants), a dozen silencers, and parts for converting semi-automatic weapons into machine guns. Berger was indicted for possession of machine guns and unregistered silencers, violations of federal law. He is a Navy veteran who lived with his father, and evidence suggested both were involved in acquiring conversion parts.In the U.S. District Court for the Eastern District of Pennsylvania, Berger raised an as-applied Second Amendment challenge. The court denied his challenge, finding that machine guns were “dangerous and unusual weapons” not commonly used for self-defense, and that silencers were not “bearable arms” under the Second Amendment. Berger then pleaded guilty to possessing a machine gun and an unregistered silencer, reserving his right to appeal the Second Amendment issue. The government dismissed the charge of possessing an unregistered machine gun as part of the plea agreement.The United States Court of Appeals for the Third Circuit reviewed Berger’s appeal de novo, focusing on pure issues of law. The court held that the Second Amendment does not protect possession of machine guns because they are not commonly used for lawful purposes and are classified as “dangerous and unusual.” Furthermore, the registration requirement for silencers under the National Firearms Act imposes only a minimal, objective burden and does not infringe upon Second Amendment rights. The court affirmed Berger’s conviction and sentence, holding that both the machine-gun ban and the silencer registration requirement are constitutional as applied to Berger. View "USA v. Berger" on Justia Law

The case concerns a noncitizen from El Salvador who lawfully entered the United States on a nonimmigrant temporary visa with work authorization. While residing in the United States, he was stopped by a Pennsylvania state trooper for a traffic violation. During the stop, the officer observed a rifle cartridge in the vehicle, leading to a search warrant and the discovery of a loaded pistol without a serial number. The individual admitted to purchasing the pistol in Maryland.He was indicted by a grand jury for violating 18 U.S.C. § 922(g)(5)(B), a statute prohibiting nonimmigrant visa holders from possessing firearms. He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The United States District Court for the Middle District of Pennsylvania denied his motion, holding the statute constitutional. After entering a conditional guilty plea, reserving his right to appeal the constitutional issue, he was sentenced to twenty-four months’ imprisonment and one year of supervised release.On appeal, the United States Court of Appeals for the Third Circuit addressed whether 18 U.S.C. § 922(g)(5)(B) is facially unconstitutional under the Second Amendment. The Court, following the framework from New York State Rifle & Pistol Ass’n v. Bruen, assumed without deciding that some noncitizens may be included among “the people” protected by the Second Amendment. The Court then considered whether the statute is consistent with the nation’s historical tradition of firearm regulation. It found that there is a longstanding historical practice of disarming individuals considered disloyal to the sovereign, including noncitizens with allegiance to another country. Concluding that § 922(g)(5)(B) is relevantly similar to these historical analogues, the Court held that the statute does not violate the Second Amendment and affirmed the conviction. View "USA v. Aleman-Lozano" on Justia Law

The case involves two parents, Emily A. Bickford and Matthew A. Bradeen, who share parental rights and responsibilities for their child. They initially agreed to a shared parenting arrangement in 2013, requiring joint decisions on matters such as the child’s religious upbringing and medical care. In 2021, disputes arose when Bradeen alleged that Bickford involved the child in religious activities without his knowledge, while Bickford claimed Bradeen tried to prevent the child’s religious training. Both parents sought sole authority over the child’s religious upbringing. After mediation resolved most issues except religion and healthcare, the District Court held hearings and found that Bickford's unilateral decisions regarding religion and medical care caused the child anxiety and endangered her relationship with Bradeen. The court also found that Bradeen was more capable of making decisions in the child’s best interest.The District Court (Portland) modified the prior order, allocating to Bradeen final decision-making authority regarding the child’s religious upbringing (especially relating to Calvary Chapel Greater Portland) and medical care. The court used a best-interest standard for medical decisions and, believing strict scrutiny was required for religious matters, found a compelling interest in protecting the child from psychological harm. Bickford’s motions for post-judgment relief were denied, and she appealed, arguing constitutional violations.The Maine Supreme Judicial Court reviewed the case and clarified that strict scrutiny does not apply to allocations of parental rights between parents, even in religious matters. The Court held that the best-interest standard governs such decisions, provided there is no religious bias. It found no evidence of religious hostility or abuse of discretion by the District Court and affirmed the judgment, upholding Bradeen’s final authority in the disputed areas. View "Bickford v. Bradeen" on Justia Law

After being arrested for domestic battery against S.O., Nicholas James Orr was subject to a criminal no contact order prohibiting communication with S.O. Despite this order, Orr repeatedly called S.O. from jail and made statements that included urging her to alter her testimony, suggesting she say the incident “didn’t happen,” and implying that her actions could “fix” his legal troubles. The State charged Orr with intimidating a witness under Idaho Code section 18-2604(3), as well as multiple violations of the no contact order.The District Court of the Sixth Judicial District denied Orr’s motion to dismiss the witness intimidation charge. Orr had argued that the statute was facially overbroad under the First Amendment and unconstitutional as applied to his conduct, asserting that the “by any manner” language of the statute criminalized protected speech, including his attempts to persuade S.O. to provide more information or clarify her statements. The district court concluded that the statute did not infringe on protected speech, as it targeted attempts to influence or prevent truthful testimony, and that Orr’s conduct could be interpreted as seeking perjury.Orr entered a conditional guilty plea to the intimidation charge, reserving the right to appeal the denial of his motion to dismiss. The Supreme Court of the State of Idaho reviewed the case de novo and affirmed the district court’s decision. The Idaho Supreme Court held that Idaho Code section 18-2604(3) is not unconstitutionally overbroad because it prohibits speech integral to criminal conduct, such as suborning perjury, which is not protected by the First Amendment. The court also held that, as applied to Orr, the statute was constitutional because his statements could reasonably be interpreted as attempts to convince S.O. to testify untruthfully. The court affirmed the denial of the motion to dismiss. View "State of Idaho v. Orr" on Justia Law

The federal government initiated a project to replace the East Wing of the White House, completing demolition in December 2025 and beginning construction of a new wing, which included both a below-ground military installation and an above-ground ballroom. The National Trust for Historic Preservation challenged aspects of the ongoing construction and sought a preliminary injunction to halt the above-ground work due to concerns about its impact on aesthetic, cultural, and historical interests.The United States District Court for the District of Columbia granted the Trust’s motion for a preliminary injunction, allowing only construction strictly necessary for security purposes above ground but permitting below-ground work to continue. The government appealed, and the United States Court of Appeals for the District of Columbia Circuit initially stayed the injunction, then ultimately affirmed the district court’s order. With the injunction set to take effect, the government sought relief from the Supreme Court of the United States.The Supreme Court granted the requested stay of the district court's injunction pending the government’s petition for certiorari. The Court held that the government is likely to succeed in showing the Trust lacks Article III standing, as the Trust’s asserted injury—distress at viewing the new ballroom’s design—does not constitute a concrete and particularized injury. The Court also found that the government would likely suffer irreparable harm from halting construction, given national security concerns and operational needs, while the Trust’s claimed harm was outweighed by these factors. The stay will remain in effect until certiorari is denied or, if granted, until the judgment is issued. View "National Park Service v. National Trust for Historic Preservation in the United States" on Justia Law

An attorney licensed in Utah challenged the state’s requirement that lawyers join the Utah State Bar and pay annual dues as a condition of practicing law. She argued that the Bar engaged in activities—such as lobbying, publishing a journal, and posting on social media—that were not sufficiently related to regulating the legal profession or improving legal services. She also objected to the procedures used by the Bar for handling members’ mandatory dues, claiming they were inadequate to protect her First and Fourteenth Amendment rights.The United States District Court for the District of Utah first dismissed the plaintiff’s claim that mandatory dues violated her rights, relying on precedent from the Tenth Circuit’s decision in Schell v. Chief Justice & Justices of Oklahoma Supreme Court. The district court then reviewed cross-motions for summary judgment on the remaining claims. It ruled for the defendants, finding that most challenged Bar activities were germane under the standard set in Keller v. State Bar of California, and that the Bar’s procedures for handling objections to expenditures and providing refunds were constitutionally sufficient.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that, under existing Supreme Court and Tenth Circuit precedent, mandatory bar dues are constitutional when used for activities germane to regulating the legal profession or improving legal services. The court also held that the correct legal standard for evaluating the Bar’s activities is the “germaneness” test from Keller, not a heightened “exacting scrutiny” standard. Because the plaintiff did not adequately challenge the district court’s germaneness findings or show that the Bar’s procedures were constitutionally deficient, the Tenth Circuit affirmed the lower court’s dismissal and summary judgment rulings. View "Pomeroy v. Utah State Bar" on Justia Law