Justia Constitutional Law Opinion Summaries

A woman in Great Falls, Montana, made a frantic 9-1-1 call pleading for help because her former partner had locked her out of their residence, and had “our” baby inside. The call abruptly ended, and police responding to the scene were unable to reestablish contact. Officers spoke to a neighbor who referenced a disturbance, and then encountered loud, indiscernible screaming from the involved apartment. Upon identifying themselves and requesting entry, the occupant, Phillip Friscia, responded angrily, repeatedly opening and closing the door, sometimes holding the child, and stated he had the right to defend himself from people in his house. Officers, concerned for the safety of those inside, forcibly entered the residence, apprehended Friscia, and found the woman and child unharmed.The State charged Friscia with felony threatening an officer and misdemeanor destruction of a communication device. Friscia moved to suppress evidence, arguing the entry was unlawful and not justified by exigent circumstances, and challenged the constitutionality of the statute under which he was charged. The Eighth Judicial District Court, Cascade County, denied both motions, finding the police entry justified by exigent circumstances based on the totality of evidence and the statute constitutionally valid. Friscia entered an Alford plea, reserving his right to appeal these decisions.The Supreme Court of the State of Montana reviewed the appeal. It held that the District Court’s factual findings regarding exigent circumstances and probable cause were not clearly erroneous and properly supported the denial of the suppression motion. The Supreme Court further held that Montana’s statute, requiring a subjective mental state, was not facially unconstitutional or overbroad, and did not violate the First Amendment under Counterman v. Colorado. The Supreme Court affirmed the District Court’s rulings and Friscia’s conviction. View "State v. Friscia" on Justia Law

In this case, the owner of a Massachusetts gun store and the store itself challenged recent amendments to state law that prohibit the sale, transfer, or possession of certain "assault-style firearms" and related magazines. The plaintiffs argued that these provisions, enacted in 2024, violated their rights under the Second Amendment, the dormant Commerce Clause, and the Equal Protection Clause of the Fourteenth Amendment. They asserted that the law infringed on their ability to keep and bear arms, imposed unconstitutional burdens on interstate commerce by affecting out-of-state manufacturers and their own business, and discriminated against them compared to individuals and businesses in other states.The United States District Court for the District of Massachusetts granted the state defendants’ motion to dismiss for failure to state a claim. The district court concluded that the plaintiffs’ Second Amendment claim was foreclosed by the First Circuit’s earlier decision in Capen v. Campbell, which upheld a similar Massachusetts firearms ban. The court also found the plaintiffs’ dormant Commerce Clause and Equal Protection Clause claims inadequately pleaded, noting that the complaint did not plausibly allege discrimination against interstate commerce or that similarly situated persons were treated differently.The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that its prior decision in Capen v. Campbell controlled and that the challenged restrictions on assault-style firearms were consistent with the Nation’s historical tradition of firearm regulation and thus did not violate the Second Amendment. The court further held that the law did not discriminate against or impose an undue burden on interstate commerce, nor did it violate equal protection, as the right to make a living is not a fundamental right and the law had a rational basis. The district court’s judgment was affirmed. View "Recchia v. Campbell" on Justia Law

The case centers on a man convicted and sentenced to death for the 1986 murder of his ex-girlfriend’s mother in Florida. On the night of the crime, he returned to his ex-girlfriend’s home after being refused entry, armed himself, and cut the phone lines before fatally shooting the woman’s father outside and, after breaking in, shooting her mother inside. The jury recommended death for both murders, but the judge imposed a life sentence for the father's death and a death sentence for the mother's, finding several aggravating factors. Since his conviction became final in 1991, he has unsuccessfully challenged his conviction and sentence in multiple state and federal proceedings.After a death warrant was signed in 2026, he filed a second successive motion for postconviction relief in the Circuit Court for Pasco County, arguing: (1) that alleged shortages of the lethal injection drug etomidate and possible deviations from execution protocols violated his constitutional rights; (2) that executing him at his advanced age would constitute cruel and unusual punishment; and (3) that the pace of executions in Florida and the circumstances of his case rendered his execution unconstitutional and a manifest injustice. The circuit court summarily denied these claims, along with his requests for public records and a stay of execution.The Supreme Court of Florida reviewed the appeal and affirmed the circuit court’s summary denial. The court held that the public records request was properly denied because it was not tied to a colorable claim for postconviction relief and found the equal protection and Eighth Amendment challenges speculative, untimely, or lacking merit. The court also rejected arguments based on the pace of executions, alleged psychological effects on prison staff, and the sufficiency of the jury’s death recommendation under current law. The motion for a stay of execution was also denied, and the mandate was ordered to issue immediately. View "Occhicone v. State" on Justia Law

During widespread civil unrest in Kenosha County, Wisconsin, following the police shooting of Jacob Blake, two photojournalists, Alyssa Schukar and Scott Olson, were documenting protests outside the Kenosha County Courthouse. The protest escalated, with some participants engaging in violent behavior and law enforcement responding with crowd-control measures, including foam baton rounds. Schukar and Olson were struck and injured by these rounds while covering the protest, though they did not observe who fired at them. Neither wore visible press credentials, but both carried cameras and equipment.Schukar and Olson brought suit in the United States District Court for the Eastern District of Wisconsin against two officers, Deputy Steven Robakowski and Officer Ryan Jacobs, alleging violations of their First Amendment rights through retaliatory targeting and Fourth Amendment rights through excessive force. The district court granted summary judgment for the officers. It found no evidence of retaliatory animus and concluded that if the officers struck the journalists, it was accidental and not a violation of their rights. The court also determined that an accidental use of force against unintended targets did not constitute a seizure under the Fourth Amendment.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that the plaintiffs failed to present evidence showing the officers intentionally targeted them because of their protected activity. It further held that, given the unsettled legal landscape, it was not clearly established in 2020 that an officer’s intentional deployment of less-than-lethal munitions that accidentally struck an unintended target constituted a Fourth Amendment seizure. As a result, the court affirmed summary judgment and held that the officers were entitled to qualified immunity. View "Schukar v Kenosha County" on Justia Law

The case concerns a defendant who, having previously been convicted of drug offenses in Virginia and Delaware, was classified under Delaware law as a “person prohibited” from possessing firearms or ammunition. In 2023, police discovered two separate firearms and corresponding ammunition in the defendant’s residence in Dover, Delaware, after the defendant voluntarily disclosed their locations. The defendant was subsequently indicted on two counts of possession of a firearm by a person prohibited and one count of possession of ammunition by a person prohibited.In the Superior Court of the State of Delaware, the defendant waived a jury trial. After a bench trial, the Superior Court found him guilty on all three counts. The court imposed separate sentences for each count, including substantial periods of incarceration and probation. The defendant appealed, arguing that his convictions were multiplicitous, in violation of the Double Jeopardy Clause of the U.S. Constitution. He contended that the Superior Court should have merged the counts into a single conviction and sentence because all the weapons and ammunition were possessed simultaneously.The Supreme Court of the State of Delaware reviewed the case. The court held that under the relevant statute, 11 Del. C. § 1448, the phrase “a deadly weapon” unambiguously sets the unit of prosecution as each individual weapon or item of ammunition, not all items collectively. Thus, the State may charge and sentence a person prohibited for each weapon or ammunition possessed at the same time. The court rejected the defendant’s arguments based on legislative history, statutory interpretation, and precedent, and affirmed the Superior Court’s judgment, holding that multiple convictions and sentences were proper under the statute. View "Abbott v. State" on Justia Law

The case centers on the convictions of two defendants for offenses related to the 2019 murder of Donnell Brockington in Baltimore City. After the shooting, the suspects fled in a vehicle, which crashed, and four individuals—including the defendants—were apprehended. Police recovered multiple firearms from the vehicle and nearby, with DNA evidence linking all four co-defendants to the weapons. At trial, a State firearms examiner testified that certain ammunition recovered from the crime scene “was fired with” a Desert Eagle pistol found in the vehicle. None of the defendants challenged the reliability of this methodology before or during trial, nor requested a Daubert hearing.Following their convictions, the defendants appealed. During the pendency of their appeal, the Supreme Court of Maryland issued a decision in Abruquah v. State concerning firearms identification testimony. The Appellate Court of Maryland subsequently reversed the convictions on plain-error review, finding that the examiner’s unqualified testimony was prohibited by Abruquah. Additionally, one defendant challenged the trial court’s decision to close the courtroom during jury deliberations and to limit attendance at the verdict, which was prompted by escalating incidents of spectator misconduct, including direct contact between a co-defendant’s father and a juror.The Supreme Court of Maryland reviewed the case and held that the admission of the unqualified firearms examiner’s testimony was not “clear or obvious” error at the time of trial or appeal, making plain-error reversal inappropriate. The Court clarified that Abruquah was a case-specific Daubert determination, not a categorical ban. Regarding the courtroom closure, the Court adopted the Kelly framework for de minimis closures but found the closures justified under Waller v. Georgia due to legitimate concerns for juror safety and deliberative integrity. The Court reversed the convictions in part and affirmed in part, remanding for further proceedings. View "State v. Thornton" on Justia Law

A man repeatedly visited the public library in Lawrence, Kansas, where he displayed various signs and flags inside the building. Library staff informed him that these actions violated library policies aimed at maintaining a peaceful environment and, after several incidents in which he refused to comply, staff called the police and temporarily suspended his library privileges. The library’s policies prohibited disruptive behavior and forbade activities—including holding signs, protesting, or similar expressive conduct—inside the library, though expressive clothing and certain other channels for communication remained allowed.He filed suit in the United States District Court for the District of Kansas against city and library officials. He alleged violations of his rights to free speech and equal protection, deprivation of procedural due process, and retaliation for protected speech. The district court granted summary judgment to the defendants on all claims. It concluded that he lacked standing for claims involving policies not applied to him, and that the challenged restrictions were content-neutral, narrowly tailored to a significant governmental interest, and left open alternative channels for expression. The court also found he was not similarly situated to others treated differently and that his due process and retaliation claims failed.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Tenth Circuit held that the library’s restrictions on signs and similar expressive activities inside were content-neutral, narrowly tailored to maintain a quiet environment for reading and study, and left open ample alternative channels for communication. It further found that the plaintiff lacked standing for certain claims, was not treated differently from similarly situated patrons, and did not engage in constitutionally protected activity supporting a retaliation claim. The grant of summary judgment to the defendants was affirmed. View "Spiehs v. Morgan" on Justia Law

A licensed clinical social worker employed as an Education Specialist by a regional education service district in Oregon displayed books in his school offices that expressed particular viewpoints on gender identity. These books, visible to students during evaluations and meetings, prompted a complaint alleging that the displays constituted a hostile bias incident under the district’s policy designed to prevent discrimination and address bias in public education settings. The district investigated, concluded that the displays violated its policy, and ordered the employee to remove the books when students were present, warning that failure to comply could result in discipline, including termination.The employee filed a lawsuit in the United States District Court for the District of Oregon alleging violations of his First Amendment free speech rights and sought a preliminary injunction to prevent the district from enforcing its directive. The district court granted the injunction in part, allowing the employee to display the books when students were not present but prohibiting displays during student-facing activities. The court reasoned that, while engaging with students as part of his official duties, the employee spoke as a government employee rather than as a private citizen and therefore was not entitled to First Amendment protection for his displays. After the employee continued to display the books in the presence of students, the district initiated additional proceedings, resulting in his termination. The employee appealed both the partial denial of injunctive relief and the denial of his motion to enforce the injunction.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decisions. The Ninth Circuit held that the employee’s display of the books while meeting with students in his official capacity was speech as a government employee and not protected by the First Amendment. Because this speech was undertaken pursuant to his professional responsibilities, the court did not apply the Pickering balancing test. The denial of preliminary injunctive relief was found not to be an abuse of discretion. View "THEIS V. INTERMOUNTAIN EDUCATION SERVICE DISTRICT" on Justia Law

Peter Navarro, a former senior adviser in the Trump administration, published materials and made public statements in 2021 about a plan to delay the certification of the 2020 presidential election. The U.S. House Select Committee investigating the January 6th Capitol attack subpoenaed Navarro for documents and deposition testimony related to these statements. Navarro refused to comply, asserting executive privilege before even seeing the subpoena and declining to engage with the Committee regarding his privilege claim. After the compliance deadline passed, the House voted to hold him in contempt, and a grand jury indicted him on two counts of contempt of Congress.In the United States District Court for the District of Columbia, Navarro moved to dismiss the indictment, arguing that former President Trump had invoked executive privilege on his behalf. After an evidentiary hearing, the district court found no evidence that Trump or his designee had actually invoked executive privilege in connection with the subpoena and denied the motion to dismiss. The court also granted a government motion to prevent Navarro from arguing at trial that a good-faith belief in executive privilege excused his noncompliance. A jury found Navarro guilty on both counts.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that only the President or a designated official can invoke executive privilege and that the district court did not clearly err in finding no such invocation occurred for Navarro’s subpoena. The court further held that executive privilege, even if properly invoked, would not have excused Navarro’s blanket refusal to comply, especially regarding his public statements and writings. It also affirmed that a mistaken belief in the applicability of executive privilege is not a defense to contempt of Congress. The appellate court affirmed the district court’s judgment. View "USA v. Navarro" on Justia Law

A defendant was charged with 44 federal offenses, including bank fraud, wire fraud, aggravated identity theft, obstruction of official proceedings, and witness tampering, arising from an alleged scheme to defraud the Paycheck Protection Program. The defendant, a Black Muslim man, co-founded a nonprofit for transitional housing and allegedly used stolen identities and fraudulent loan applications for the nonprofit and two shell entities. He represented himself at trial, arguing law enforcement targeted him due to his race and religion.The United States District Court for the Northern District of California presided over the trial. During jury selection, an alternate juror expressed strong negative reactions to the defendant’s defense, stating he could not put aside his personal experiences and doubted his ability to be impartial. Despite the defendant’s request to excuse this juror, the district court deferred its inquiry and allowed the juror to serve as an alternate. When a regular juror was dismissed during trial, the alternate joined the deliberating jury after a brief, belated colloquy in which he claimed to have moved past his initial bias. The defendant objected, arguing the juror remained biased. The jury subsequently convicted the defendant on all counts, and the district court sentenced him to 204 months’ imprisonment.The United States Court of Appeals for the Ninth Circuit reviewed the proceedings and held that the district court abused its discretion by failing to promptly investigate the alternate juror’s bias and by conducting an inadequate inquiry after the juror had heard evidence. The appellate court found that these errors deprived the defendant of his Sixth Amendment right to an impartial jury and constituted structural error. The Ninth Circuit vacated the convictions, reversed the district court’s judgment, and remanded the case for a new trial. View "USA V. COLAR" on Justia Law