Justia Constitutional Law Opinion Summaries

Between December 2017 and February 2018, Derby Clerfe purchased nine 9mm handguns from a Pennsylvania sporting goods store. Federal authorities, finding this purchasing pattern suspicious, interviewed Clerfe, who admitted arranging for the guns to be shipped to Haiti through a third party, without declaring them as required by law. He acknowledged the guns may have been concealed and had not yet arrived in Haiti. Clerfe was charged with conspiracy to violate U.S. laws prohibiting the export of firearms without proper filing, as well as transferring firearms to an unlicensed out-of-state resident.The U.S. District Court for the Western District of Pennsylvania reviewed the charges. Clerfe moved to dismiss the indictment on the grounds that the laws he was charged under violated the Second Amendment, constituted an unconstitutional delegation of legislative authority to the executive branch, and were unconstitutionally vague. The District Court denied his motion. Clerfe then pleaded guilty to one count of conspiracy but reserved the right to appeal the denial of his motion on Second Amendment and non-delegation grounds.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the laws prohibiting Clerfe from exporting handguns to Haiti did not violate the Second Amendment because the right to “keep and bear Arms” does not encompass sending firearms abroad in violation of export laws. The court further held that the Arms Export Control Act’s delegation to the President to designate “defense articles” for export control satisfies the constitutional “intelligible principle” standard, and thus does not violate the non-delegation doctrine. Accordingly, the Third Circuit affirmed the District Court’s denial of Clerfe’s motion to dismiss the indictment. View "USA v. Clerfe" on Justia Law

In this case, organizations that represent indigent and low-income litigants challenged the widespread unavailability of official court reporters in California’s superior courts for civil, family, and probate proceedings. These organizations documented that, despite prior assurances, many indigent litigants appear in court and find that no court reporter is present, even when properly requested. As a result, such litigants are often forced either to accept repeated continuances—delaying urgent matters like domestic violence restraining orders and child custody—or to proceed without a verbatim record, which severely impairs their ability to seek appellate review.Previously, the Supreme Court of California had ruled in *Jameson v. Desta* that when a superior court does not routinely provide court reporters in civil cases but allows parties who can afford it to hire private reporters, the court must ensure that indigent litigants receive access to an official verbatim record. Despite this, the petitioners alleged and the courts largely conceded that a chronic shortage of court reporters had rendered this guarantee largely ineffective. Some superior courts responded by issuing general orders allowing electronic recording in certain cases involving fundamental rights, but these policies were limited in scope and not uniformly adopted.The Supreme Court of California reviewed this original proceeding and held that, under the in forma pauperis doctrine articulated in *Jameson v. Desta*, superior courts have a ministerial duty to provide indigent litigants, upon request, with meaningful access to an official verbatim record of proceedings in all civil matters. This duty includes using electronic recording if neither an official nor a private court reporter is available, notwithstanding statutory restrictions. The court issued a writ of mandate directing the respondent superior courts to comply with this obligation. Each party was ordered to bear its own costs. View "Family Violence Appellate Project v. Super. Ct." on Justia Law

In 2004, a fourteen-year-old girl was sexually assaulted in Anoka County, Minnesota. She provided evidence for a rape kit, which was submitted to the Anoka County Sheriff’s Office. Detective Johnson was assigned to her case and assured her mother that no DNA was obtained, though in reality the kit was never tested. The suspect was charged but not convicted. In 2015, it was discovered that the Sheriff’s Office had hundreds of untested rape kits, including hers. Sixteen years after the assault, her kit was finally tested, revealing DNA evidence implicating the original suspect, and criminal charges were pursued again.After these events, she brought suit against Anoka County, Sheriff Stuart, and Detective Johnson in the United States District Court for the District of Minnesota. She asserted claims under the Fourteenth Amendment and the Minnesota Constitution for equal protection violations, a claim under the Minnesota Human Rights Act, a “failure to train” claim under 42 U.S.C. § 1983, and state tort claims for negligence and intentional infliction of emotional distress (IIED). The district court dismissed her MHRA and negligence claims but allowed the other claims to proceed, finding she had standing in light of Eighth Circuit precedent.On appeal, the United States Court of Appeals for the Eighth Circuit concluded that the plaintiff lacked standing to bring her federal constitutional claims for alleged failures to investigate or train, following Supreme Court and Eighth Circuit precedent holding that crime victims generally lack standing to challenge law enforcement or prosecutorial discretion in investigating crimes, even when alleging class-based discrimination. The Eighth Circuit vacated the district court’s judgment on the federal claims and remanded with instructions to dismiss those claims for lack of standing. The court remanded the IIED claim for the district court to determine whether standing existed for that state-law claim. View "Doe v. Anoka County" on Justia Law

The defendant pleaded guilty in 2014 to multiple offenses, including two counts of attempted murder and a firearm enhancement, as part of a plea deal. He agreed to a stipulated sentence of 25 years in prison, which included the upper term for attempted murder. He also admitted a prior prison term enhancement. Years later, after legislative changes invalidated certain prison prior enhancements and amended sentencing rules for upper terms, the defendant was resentenced under Penal Code section 1172.75. The trial court dismissed the prison prior enhancement and reduced his controlled substance conviction to a misdemeanor, lowering his overall sentence to 23 years and 4 months.At the Orange County Superior Court, the judge imposed the upper term for attempted murder during the original sentencing pursuant to the plea agreement. During resentencing under section 1172.75, the court removed the prison prior enhancement but reimposed the upper term for attempted murder without requiring a jury finding or defendant stipulation regarding aggravating factors. The defendant appealed, arguing that recent amendments to Penal Code section 1170, subdivision (b)—requiring a jury finding or stipulation for upper term sentencing—should apply retroactively at resentencing.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that section 1172.75, subdivision (d)(4), allows reimposition of the upper term at resentencing if it was originally imposed, even without a jury finding or stipulation. The court also found no Sixth Amendment violation because no new judicial factfinding occurred, and rejected the defendant’s Equal Protection claim, concluding that the Legislature had rational reasons to treat resentencing under section 1172.75 differently from other statutes. The judgment was affirmed. View "People v. McAlister" on Justia Law

Cody Henderson, a resident of New Holland, Ohio, was stopped and cited by police officers on multiple occasions while driving his black Prius. On September 13, 2022, he was stopped for speeding, and later cited for several infractions including expired registration. On September 22, officers again stopped him for driving with expired tags, impounded his car, and conducted an inventory search. Henderson objected, refused to comply with officer instructions, and was arrested for obstruction of official business. The search revealed hemp-related substances, which were later determined to be legal, and all charges were dismissed. Henderson subsequently filed a federal lawsuit alleging violations of his constitutional rights and state-law claims.The United States District Court for the Southern District of Ohio dismissed the claims against Officer Pate (who had died prior to the suit) and against the Village of New Holland. Most claims against Officer Lawless were also dismissed, except for Henderson’s Fourth Amendment and malicious prosecution claims. The district court denied qualified immunity to Officer Lawless on these remaining claims, allowing them to proceed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that Officer Lawless had probable cause for the traffic stop, inventory search, and subsequent arrest for obstruction of official business. The inventory search was found lawful under the Fourth Amendment, as it followed standardized procedures and was not pretextual. The court also determined that the state-law malicious prosecution claim failed because probable cause existed for the arrest. Accordingly, the Sixth Circuit reversed the district court’s denial of qualified immunity and dismissed the remaining claims against Officer Lawless. View "Henderson v. Village of New Holland" on Justia Law

The plaintiffs in this case are residents of Hillman Ridge Road in Brown County, Ohio. They experienced a cessation of direct mail delivery to their homes after 2017, following an incident involving a neighbor and a mail carrier. As a result, they were required to retrieve their mail from a distant location and travel to a nearby town for parcels. Other delivery services continued to serve their properties, and the Postal Service continued direct delivery on similar roads in the area. The plaintiffs argued that the Postal Service’s refusal to deliver directly to their homes constituted unconstitutional, unreasonable discrimination.The plaintiffs filed suit in the United States District Court for the Southern District of Ohio, naming the United States Postal Service and two officials as defendants. They asserted a “class of one” equal protection claim, alleging that the Postal Service’s actions violated their constitutional rights. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction. The district court held that the plaintiffs’ dispute belonged exclusively before the Postal Regulatory Commission, not in federal district court, and granted the dismissal. Plaintiffs then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. It held that Congress intended for claims concerning unreasonable discrimination in mail service—such as those under 39 U.S.C. § 403(c)—to be addressed first by the Postal Regulatory Commission under the administrative procedures of the Postal Accountability and Enhancement Act. The court found that the statutory scheme precludes district court jurisdiction over such claims, even those framed as constitutional issues. The court affirmed the district court’s dismissal for lack of jurisdiction, holding that plaintiffs must pursue their claim through the Commission before seeking judicial review. View "Klein v. USPS" on Justia Law

A suspect was interviewed by police regarding a homicide after being advised of his Miranda rights. He stated he understood those rights and initially agreed to speak with the officers, but during the interview, he made an ambiguous comment about whether he should continue without an attorney. Rather than clarifying whether the suspect actually wanted counsel, the officers continued questioning without pause. The suspect made admissions during the interview, and evidence from that interview was later used to convict him at trial for first-degree murder and tampering with evidence.Prior to trial in the Superior Court for the State of Alaska, Third Judicial District, Kodiak, the defendant moved to suppress his statements from the interview, arguing that his ambiguous reference to counsel required the officers to stop and clarify whether he wanted an attorney. The superior court denied the motion to suppress, finding that the defendant had knowingly waived his Miranda rights and that the ambiguous statement did not require clarification. The defendant was convicted by a jury. On appeal, the Alaska Court of Appeals reversed the conviction, holding that under the Alaska Constitution, police are required to stop and seek clarification when a suspect makes an ambiguous post-waiver reference to counsel.The Supreme Court of the State of Alaska reviewed the case after the State petitioned for hearing, asking the court to adopt the federal standard from Davis v. United States, which does not require a “stop and clarify” rule. The Alaska Supreme Court held that, under article I, sections 9 and 11 of the Alaska Constitution, law enforcement officers must stop questioning and clarify any ambiguous request for counsel—even after a suspect has waived Miranda rights. The court affirmed the decision of the court of appeals, reversed the conviction, and required suppression of the defendant’s statements made after the ambiguous request. View "State v. Ridenour" on Justia Law

A multi-state utility company operating a gas-fired power plant in Washington alleged that the state's Climate Commitment Act (CCA) impermissibly discriminated against interstate commerce by allocating no-cost greenhouse gas emissions allowances only for electricity sold to Washington customers. Under Washington’s Clean Energy Transformation Act (CETA) and the CCA, utilities serving in-state customers receive no-cost allowances to offset compliance costs, while electricity exported to customers in other states does not receive this benefit. The company argued that this scheme increased costs for its non-Washington customers and potentially its shareholders, as out-of-state sales from the Washington facility required purchasing emissions allowances at auction.The United States District Court for the Western District of Washington reviewed the complaint and found that the electricity generated for export was not subject to CETA’s decarbonization mandates, distinguishing it from in-state electricity. The district court concluded that the two categories were not similarly situated for purposes of Dormant Commerce Clause analysis. The court reasoned that utilities serving Washington customers were already subject to more aggressive decarbonization requirements under CETA, justifying the allocation of no-cost allowances under the CCA. The district court dismissed the complaint with prejudice, finding no plausible claim of unconstitutional discrimination, and denied the motion for preliminary injunction as moot.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal and denial of the injunction. The Ninth Circuit held that because the regulatory schemes governing in-state and exported electricity are distinct, the emissions associated with each are not similarly situated. Therefore, Washington’s allocation of no-cost allowances did not violate the Dormant Commerce Clause. The court further held that dismissal without leave to amend was appropriate, as any amendment would be futile. The decision was affirmed. View "PACIFICORP V. SIXKILLER" on Justia Law

A town administrator in Grand Chute, Wisconsin, was terminated by a newly elected faction on the town’s Board of Supervisors. The administrator, who had served since 2008, claimed his firing was retaliation for cooperating with a state Department of Justice investigation into alleged corruption by a newly elected supervisor. That supervisor had previously been involved in litigation against the town and was later indicted, though ultimately acquitted, on unrelated corruption charges. The administrator’s relationship with the new board members deteriorated, and he was perceived as politically aligned with their rivals and critical of their policies.The administrator sued the Town and individual supervisors in the United States District Court for the Eastern District of Wisconsin under 42 U.S.C. § 1983, asserting First Amendment retaliation. The supervisor also filed a counterclaim alleging the administrator had set him up for prosecution. The district court granted summary judgment for the defendants in both actions, finding the administrator’s termination did not violate the First Amendment and that qualified immunity applied due to unclear precedent regarding the firing of policymaking officials for political speech. The court also rejected the supervisor’s counterclaim, finding no evidence of state action or differential treatment required for an equal protection class-of-one claim.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The Seventh Circuit affirmed, holding that the individual defendants were entitled to qualified immunity because existing precedent did not clearly establish that firing a policymaking official under these circumstances violated the First Amendment. The court also affirmed dismissal of the counterclaim, finding neither a viable First Amendment retaliation nor an equal protection claim. View "March v. Wolff" on Justia Law

Arizona amended its election laws in 2022, introducing two provisions: one requires county recorders to cancel a voter’s registration in their county if the voter registers in a new county (“Cancellation Provision”), and the other criminalizes knowingly providing a “mechanism for voting” to someone registered in another state (“Felony Provision”). Three organizations engaged in voter registration and education activities claimed these provisions would interfere with their efforts, and sought to enjoin enforcement. They argued that the Cancellation Provision would lead to improper removal of voters and that the Felony Provision was vague and could chill their constitutionally protected activities.The United States District Court for the District of Arizona granted a preliminary injunction, barring enforcement of both provisions. The Arizona Attorney General appealed. A three-judge panel of the United States Court of Appeals for the Ninth Circuit vacated the injunction, finding that the organizations lacked standing for the Cancellation Provision and were unlikely to succeed on the merits regarding the Felony Provision. The case was then reheard en banc after the prior panel’s opinion was vacated.The United States Court of Appeals for the Ninth Circuit, sitting en banc, held that the organizations lacked standing to challenge the Cancellation Provision because they did not clearly show that it directly affected or interfered with their core activities, as required by FDA v. Alliance for Hippocratic Medicine. The court further held that the organizations had standing to challenge the Felony Provision due to a credible threat of prosecution, but were unlikely to succeed on the merits, as the statutory context indicated that “mechanism for voting” likely refers only to a ballot or ballot envelope, not to voter registration or education activities. The court vacated the preliminary injunction and remanded the case. View "ARIZONA ALLIANCE FOR RETIRED AMERICANS V. MAYES" on Justia Law