Justia Constitutional Law Opinion Summaries

A group of individuals who wished to protest outside a high-profile murder trial in Massachusetts were prohibited from doing so by a Superior Court judge’s order establishing a 200-foot buffer zone around the courthouse, including nearby sidewalks and streets. After the buffer zone was imposed, the plaintiffs—demonstrators—filed suit in federal court against various public officials and entities, alleging violations of their First Amendment and due process rights.The United States District Court for the District of Massachusetts initially denied a preliminary injunction against the buffer zone, but the United States Court of Appeals for the First Circuit vacated that denial and remanded, suggesting that a restriction more closely tailored to demonstrations intended to interfere with justice might be permissible. In response, the Superior Court judge amended the order to include a requirement of intent to interfere with the administration of justice or influence trial participants. The district court then partially granted and partially denied a renewed motion for a preliminary injunction: it found the revised order survived a facial First Amendment challenge but agreed with plaintiffs that there had been unconstitutional as-applied enforcement, granting limited relief.After the murder trial concluded and the buffer zone order expired by its own terms, the plaintiffs continued to appeal the denial of broader injunctive relief. The United States Court of Appeals for the First Circuit held that the case was moot because the order was no longer in effect and there was no reasonable expectation the same plaintiffs would again face a similar restriction. The court determined that neither injunctive nor declaratory relief was available and that the “capable of repetition, yet evading review” exception did not apply. As a result, the First Circuit vacated the district court’s partial denial of the preliminary injunction and ordered dismissal of that portion of the case, leaving the remainder to the district court. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

A minor child, who had been in her grandmother’s custody due to her mother’s intellectual disabilities, became the subject of a child in need of assistance (CINA) case after concerns arose about missed medical appointments and poor academic performance. The Department of Social Services petitioned for CINA status, but the juvenile court initially allowed the child to remain with her grandmother under protective supervision. Over time, further review hearings were held, and eventually a magistrate recommended removing the child from her grandmother’s custody. The child and her grandmother objected, leading to a de novo exceptions hearing.At the exceptions hearing, the Circuit Court for Worcester County, sitting as a juvenile court, excluded the child from the hearing over the objection of her counsel, reasoning generally that it was inappropriate for children under 15, especially those with developmental delays, to attend such contested proceedings. The court later removed the child from her grandmother’s custody and placed her with the Department. The Appellate Court of Maryland affirmed the juvenile court, finding no abuse of discretion, and distinguished this case from prior precedent by concluding the juvenile court had considered the child’s due process rights.The Supreme Court of Maryland reviewed the case and held that, although the appeal was moot because the CINA proceedings had been terminated and custody restored to the grandmother, the case presented an issue of public importance warranting review. The Court held the juvenile court violated the child’s procedural due process rights by excluding her from her own CINA hearing without making individualized findings or balancing her due process interests against any potential harm from her presence. The Court articulated a new test requiring courts to make specific findings and narrowly tailor any exclusion of a child party. The judgment of the Appellate Court of Maryland was reversed. View "In re: K.B." on Justia Law

Two naturalized U.S. citizens, who previously obtained lawful status through the Special Immigrant Juvenile (SIJ) program after state courts found parental abuse, neglect, or abandonment, sought to confer immigration benefits to their noncitizen mothers. Both mothers’ applications were denied by United States Citizenship and Immigration Services (USCIS), invoking an exclusion clause in the SIJ statute, 8 U.S.C. § 1101(a)(27)(J)(iii)(II), and an implementing regulation prohibiting parents of SIJ recipients from receiving immigration benefits based on parentage. The plaintiffs challenged both USCIS’s interpretation of the exclusion clause and the constitutionality of the clause, arguing it violated equal protection.The United States District Court for the Eastern District of Virginia, reviewing cross-motions for summary judgment, ruled in favor of USCIS. The court held that the regulation was consistent with the plain text of the exclusion clause and rejected the equal protection claim, concluding that plaintiffs lacked a direct constitutional injury and, in the alternative, that the exclusion survived rational basis review. Plaintiffs appealed, maintaining their APA and equal protection challenges.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the exclusion clause’s plain text establishes a permanent bar, preventing any parent of an SIJ recipient from receiving immigration benefits based solely on parentage, regardless of whether the parent was abusive or not. The court also held that USCIS’s regulation is consistent with the statute. On the equal protection claim, the Fourth Circuit found differential treatment but determined that the exclusion clause survives rational basis review, as it is rationally related to protecting children from harm. The judgment of the district court was affirmed. View "Fuentes v. Citizenship and Immigration Services" on Justia Law

Texas enacted a law imposing new requirements on certain social media platforms, termed "digital service providers" (DSPs), to restrict minors’ access to specific categories of content. These requirements included monitoring and filtering content deemed harmful, prohibiting targeted ads to minors, preventing unlawful ads, verifying user age for access to certain material, and requiring age registration for account creation. Two groups challenged the law: one group, including technology industry organizations, contested the monitoring and filtering requirement; another group, comprised of a student coalition, individuals, and an ad agency, challenged several provisions, including the monitoring and filtering, targeted ads, unlawful ads, and age-verification requirements.In the United States District Court for the Western District of Texas, both plaintiffs sought preliminary injunctions against enforcement of the law. The district court granted injunctions in part, enjoining the monitoring and filtering requirements for both groups, and enjoining the targeted ads, unlawful ads, and age-verification requirements for the student coalition group. The court found these provisions likely unconstitutional or vague, and held that the plaintiffs had standing based on the chilling effect on their speech and listening rights. The Attorney General of Texas appealed, and the United States Court of Appeals for the Fifth Circuit consolidated the cases.The United States Court of Appeals for the Fifth Circuit held that the student coalition plaintiffs lacked standing to challenge the monitoring and filtering, targeted ads, and unlawful ads requirements, as they were not directly regulated and failed to show a substantial risk of imminent harm. Their challenge to the age-verification requirement was foreclosed by Supreme Court precedent. However, the court held that the monitoring and filtering requirement, as challenged by the industry groups, is preempted by Section 230 of the Communications Decency Act. The Fifth Circuit affirmed the district court’s injunction as to the industry group, but vacated and remanded the injunction as to the student coalition plaintiffs. View "Computer & Communications Industry Association v. Paxton" on Justia Law

A long-serving correctional officer at the District of Columbia Department of Corrections was terminated from her position after nearly three decades of service. During the COVID-19 pandemic, she became increasingly vocal about perceived failures in the Department’s response to the crisis. In her role as a union leader, she forwarded internal Department emails to union attorneys and participated in a local television interview criticizing the Department’s pandemic management. The Department launched an investigation, ultimately determining that she violated confidentiality policies and terminated her employment, despite a hearing officer’s recommendation for a lesser penalty.After her termination, she filed suit in D.C. Superior Court against the Department’s leadership, alleging that her firing violated her First Amendment rights. The defendants removed the case to the United States District Court for the District of Columbia, where both sides moved for summary judgment. The district court found triable issues of fact regarding whether her termination was motivated by protected speech and denied qualified immunity to the individual defendants. The defendants sought reconsideration, which was denied, and then appealed to the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit held that the officials were entitled to qualified immunity with respect to her claim that she was fired for forwarding confidential emails, finding no violation of a clearly established First Amendment right in those circumstances. However, the court affirmed the denial of qualified immunity for the claim that she was fired for giving a media interview, concluding that if her termination was motivated by the interview, it would violate clearly established First Amendment law. The case was remanded for further proceedings. View "Johnson v. DC" on Justia Law

The case concerns a defendant who was arrested after his girlfriend reported to police that he had struck her, taken her handgun, chambered a round, and threatened her with it. Forensic evidence later confirmed his DNA on the weapon. The defendant gave conflicting accounts, initially denying knowledge of the gun, then claiming he took it from his girlfriend to protect himself. Officers arrested him, and he was charged in state court with domestic violence and illegal firearm possession. While out on bond, federal prosecutors indicted him for being a felon in possession of a firearm after an earlier felony conviction. During execution of a federal arrest warrant, officers found a stolen rifle in the home. The government offered a plea deal involving a single count, which the defendant declined, resulting in a superseding indictment on two counts.The United States District Court for the Northern District of Ohio denied the defendant’s motion to suppress the rifle and his motion to dismiss on Second Amendment grounds. The defendant ultimately pleaded guilty to both counts without a written plea agreement. At sentencing, the district court applied an enhancement for possessing a firearm in connection with a felony offense, based on evidence that he had threatened his girlfriend with the handgun, and imposed a 100-month prison sentence. The defendant appealed, raising constitutional arguments and challenging the sentencing enhancement.The United States Court of Appeals for the Sixth Circuit held that, because the defendant pleaded guilty unconditionally and did not comply with Federal Rule of Criminal Procedure 11(a)(2), he waived his right to appeal pre-plea constitutional issues. The court declined to address his ineffective assistance of counsel claim on direct appeal, finding the record undeveloped. Reviewing the sentencing enhancement for clear error, the court found ample evidence to support the district court’s application of the enhancement and affirmed the sentence. View "United States v. Williams" on Justia Law

In 2019, a man was indicted in Coahoma County, Mississippi, on three charges: sexual battery of a child under fourteen, felonious child abuse, and exposing another to HIV. The case involved his eight-year-old daughter, who moved to live with him that year. After the child disclosed abuse to her older sister, she was taken to the hospital, where injuries consistent with sexual abuse were observed. Medical professionals and law enforcement became involved, and the child underwent further examinations and interviews. During the investigation, the defendant admitted to law enforcement that he was HIV positive.A jury in the Coahoma County Circuit Court found the defendant guilty on all three counts. The trial court sentenced him to twenty years for sexual battery, and five years each for child abuse and exposing another to HIV, all to be served concurrently. The defendant’s motion for a new trial was denied. On appeal to the Supreme Court of Mississippi, the defendant challenged only his conviction for exposing another to HIV, arguing the trial court violated his Confrontation Clause rights by admitting Mississippi Department of Health records without the opportunity to cross-examine their custodian and that the State presented insufficient evidence of knowing exposure.The Supreme Court of Mississippi held that the Confrontation Clause argument was procedurally barred because it was not raised at trial and, alternatively, the admitted records were non-testimonial business records not subject to the Confrontation Clause. The court also determined that the State had presented sufficient evidence for a rational juror to convict under the plain language of the statute, which required proof that the defendant was HIV positive and knowingly exposed the child. The conviction and sentence were affirmed. View "Sims v. State of Mississippi" on Justia Law

The defendant, after previously pleading guilty to aggravated criminal damage to property under Louisiana law, was found in possession of a firearm. His earlier offense involved intentionally damaging vehicles during a police traffic stop, endangering human life, which led to a three-year sentence. After serving his sentence, he was again found with a firearm, resulting in an indictment for possession of a firearm by a convicted felon under 18 U.S.C. § 922(g)(1).The United States District Court for the Western District of Louisiana reviewed the defendant’s motion to dismiss the indictment, in which he argued that § 922(g)(1) was unconstitutional as applied to him. The district court denied the motion. The defendant then entered a conditional guilty plea, reserving the right to appeal the denial, and was sentenced to 56 months’ imprisonment.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the constitutionality of § 922(g)(1) as applied to the defendant, considering whether the government's justification for permanent disarmament was supported by a historical tradition consistent with the Second Amendment, as outlined in New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The Fifth Circuit found that the government had not met its burden to demonstrate a relevant historical analogue for disarming individuals with a property crime predicate like the defendant’s. The court declined to expand precedent by treating aggravated property damage as sufficiently violent for permanent disarmament under historical going-armed laws.The Fifth Circuit vacated the district court’s order denying the motion to dismiss and remanded the case for reconsideration. The main holding was that, absent sufficient evidence of a historical tradition supporting disarmament for this type of predicate felony, the government had not justified the application of § 922(g)(1) to the defendant. View "USA v. Debrow" on Justia Law

Raymond Carrin was a federal detainee diagnosed with Hepatitis C who sought medical treatment while in custody at the Federal Detention Center in Tallahassee, Florida. Despite Carrin’s repeated requests and visible deterioration over more than a year—including emergency hospitalizations and symptoms consistent with advanced liver disease—medical staff did not provide him with the direct-acting antiviral treatment prescribed for his condition. The facility’s staff indicated that treatment would only begin once Carrin was transferred to his designated institution, a transfer that was delayed for various reasons. Carrin eventually died from hepatic cirrhosis without receiving the necessary medication. He did not file a formal grievance or seek relief under the prison’s Administrative Remedy Program (ARP) before his death.Carrin’s estate brought suit in the United States District Court for the Northern District of Florida against two federal prison officials, alleging violations of Carrin’s Fifth and Eighth Amendment rights and seeking damages under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court initially denied the defendants’ motions to dismiss and for summary judgment. However, after the Eleventh Circuit’s decision in Johnson v. Terry, 119 F.4th 840 (11th Cir. 2024), the court granted judgment on the pleadings for the defendants, holding that the presence of the ARP constituted a special factor counseling against extending Bivens to these claims, and that Carrin’s case differed meaningfully from prior Supreme Court Bivens precedents.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that both the Eighth and Fifth Amendment claims arose in a new context distinct from Carlson v. Green, 446 U.S. 14 (1980), and that the existence of the ARP—regardless of its adequacy or accessibility to the estate—was a special factor precluding the extension of Bivens remedies. View "Carrin v. Smiledge" on Justia Law

Stanford Williams was tried three times for the 1993 murder of Omar Massey. The first trial ended in a hung jury, and the second trial was interrupted when a key witness, John Faingnaert, changed his expected testimony regarding Williams’s exposure to gun residue. Williams’s attorney, John Elash, contemplated becoming a witness to rebut Faingnaert but acknowledged he could not continue representing Williams if he did so. The trial court concluded that Elash could not waive a potential ineffective assistance claim and, after discussion, granted a mistrial. Williams was convicted at his third trial and sentenced to life in prison.Following his conviction, Williams argued that the third trial violated his protection against double jeopardy, asserting that he had not requested or consented to the mistrial in the second trial. The Allegheny County Court of Common Pleas rejected this claim, finding that Williams had moved for a mistrial. The Pennsylvania Superior Court affirmed, holding that Williams waived his double jeopardy claim by not raising it before the third trial and that the claim lacked merit because he had requested the mistrial. Williams sought post-conviction relief, and the same trial judge found again that Williams requested the mistrial; the Superior Court affirmed this finding.Williams then filed for habeas corpus relief in the United States District Court for the Western District of Pennsylvania. The District Court granted his petition, holding that the third trial violated double jeopardy and that his counsel was ineffective for failing to raise the claim. On appeal, the United States Court of Appeals for the Third Circuit applied AEDPA deference to the state court’s findings and concluded that Williams did not provide clear and convincing evidence that the state court erred in finding he requested a mistrial. The Third Circuit held that the third trial did not violate the Double Jeopardy Clause and that Williams’s counsel was not ineffective for failing to raise a meritless double jeopardy claim. The District Court’s order was reversed. View "Williams v. Superintendent Fayette SCI" on Justia Law