Justia Constitutional Law Opinion Summaries

Law enforcement conducted a two-month investigation in New Orleans into two relatives, Terence Wilson and Travis Enclade, suspected of trafficking methamphetamine, fentanyl, and heroin. Surveillance techniques included pole cameras, physical observation, GPS tracking, and phone analysis at several residences linked to the defendants. Footage and investigative findings suggested hand-to-hand drug transactions, shared access to a stash house, and the presence of firearms. During a jailhouse call following Wilson’s arrest, coded language was used to direct Enclade to narcotics later found in a kitchen cabinet. Subsequent searches of three residences uncovered large quantities of drugs, distribution materials, and multiple firearms.The United States District Court for the Eastern District of Louisiana presided over the trial, where both defendants were convicted by a jury of conspiracy to distribute controlled substances. Wilson was also convicted of possession with intent to distribute and being a felon in possession of firearms, while Enclade was convicted of being a felon in possession of firearms. Both were acquitted on one count related to possessing firearms in furtherance of drug trafficking. The district court sentenced Enclade to 288 months and Wilson to 240 months, both below the Guidelines range. Defendants challenged the sufficiency of the evidence, evidentiary rulings, jury instructions, the conduct of the prosecutor, denial of a continuance, their sentences, and the constitutionality of 18 U.S.C. § 922(g)(1).The United States Court of Appeals for the Fifth Circuit reviewed the convictions and sentences. The court held that the evidence was sufficient for all convictions, that any evidentiary errors or improper prosecutorial remarks did not prejudice the defendants, and that the district court did not abuse its discretion in its rulings. The court further held that § 922(g)(1) was constitutional and that Enclade’s sentence was reasonable. The Fifth Circuit affirmed the district court’s judgment. View "USA v. Enclade" on Justia Law

A group of registered voters in South Carolina, all under the age of sixty-five, challenged a provision of state law that restricts “no excuse” absentee-by-mail voting to voters sixty-five years of age or older. These plaintiffs argued that the statute unconstitutionally discriminates against them on account of age, in violation of the Twenty-Sixth Amendment, and also violates the Equal Protection Clause of the Fourteenth Amendment. The law at issue allows voters sixty-five and older to vote absentee by mail for any reason, while voters under sixty-five can only do so if they meet specific, narrow criteria such as disability, military service, or certain employment conflicts.The case was initially heard in the United States District Court for the District of South Carolina, where the court granted summary judgment in favor of the defendants—the South Carolina State Election Commission and related officials—on both constitutional claims. The district court found that the plaintiffs did not demonstrate a violation of either the Twenty-Sixth Amendment or the Equal Protection Clause. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. This court held that the plaintiffs have standing and that South Carolina’s age-based absentee-by-mail voting scheme violates the Twenty-Sixth Amendment because it abridges the right to vote on account of age by providing greater ballot access to older voters. However, the court affirmed the district court’s decision to dismiss the Equal Protection claim, as age is not a suspect classification under the Equal Protection Clause and the plaintiffs did not challenge the law under rational basis or Anderson-Burdick scrutiny. The Fourth Circuit reversed the district court’s judgment on the Twenty-Sixth Amendment claim, affirmed the Equal Protection ruling, and remanded the case for appropriate remedy. View "Grant v. Belangia" on Justia Law

A kindergarten teacher in Mississippi was frustrated after being unable to use a remote entry service to unlock her car and, during a customer service call, told an agent that she was aggravated and might “kill some little kindergarteners.” She reiterated this after her issue was resolved, saying the agent had “saved 20 children from being killed.” The agent reported the statements to the police. The responding officers met with the teacher, who admitted to the remarks but said they were taken out of context. After consulting with an Assistant District Attorney, the teacher was charged with making terroristic threats, processed, and jailed. A grand jury declined to indict her.The teacher filed suit in the United States District Court for the Southern District of Mississippi against the city, the chief of police, and an officer, alleging false arrest, false imprisonment, malicious prosecution under state and federal law, and a Fourteenth Amendment violation. The defendants moved for summary judgment, asserting qualified immunity. The district court denied their motion, and the defendants appealed.The United States Court of Appeals for the Fifth Circuit held that the officers were entitled to qualified immunity, finding that the facts known to the officers at the time provided probable cause for arrest, defeating the constitutional claims. The court also found that, even if the officers erred, the right to be free from arrest under these circumstances was not clearly established. The appellate court reversed the district court’s denial of qualified immunity and declined to exercise pendent jurisdiction over the state law and municipal liability claims, remanding those for further proceedings. View "Bonds v. Woodall" on Justia Law

In 2017, Indiana enacted a statute known as the “aid-or-assist” law, which prohibits any person from knowingly or intentionally assisting an unemancipated pregnant minor in obtaining an abortion without fulfilling the state’s parental consent and notice requirements. Planned Parenthood, a nonprofit operating health centers in Indiana, regularly provides minors with factually accurate information and referrals about lawful abortion services in neighboring states, particularly after Indiana enacted more restrictive abortion laws following Dobbs v. Jackson Women’s Health Organization. Both parties agreed that, without adherence to Indiana’s parental consent law, providing such information would violate the aid-or-assist statute, exposing Planned Parenthood and its physicians to civil liability and professional discipline.After the law’s passage, Planned Parenthood filed suit in the United States District Court for the Southern District of Indiana, challenging the statute under the First Amendment as applied to its provision of information and referrals to minors about lawful out-of-state abortion services. The district court initially granted a preliminary injunction, and after changes in federal and state abortion law, ultimately issued a permanent injunction preventing enforcement of the aid-or-assist law as applied to Planned Parenthood’s speech and referrals about legal abortion practices in other states. The district court reasoned that the statute was a content-based restriction on protected speech and failed strict scrutiny.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the permanent injunction, with one modification: it removed the Commissioner of Health as a defendant because the Commissioner no longer had authority to provide relief. The Seventh Circuit held that Planned Parenthood’s provision of information and referrals about legal out-of-state abortion services was protected speech under the First Amendment. The court found that Indiana’s law, as applied, was a content- and viewpoint-based restriction that failed strict scrutiny, as it was not narrowly tailored to serve compelling state interests. The injunction was affirmed as modified. View "Planned Parenthood Great Northwest, Hawai'i v Commissioner of the Indiana State Department" on Justia Law

A pharmaceutical company that manufactures both branded and generic drugs challenged the federal agency rules implementing the Medicare Drug Price Negotiation Program created under the Inflation Reduction Act of 2022. Specifically, the company objected to two rules: first, the agency’s grouping of two drugs with the same active ingredient and manufacturer, but approved under separate applications, as one “qualifying single source drug” for price negotiation; and second, the agency’s requirement that a generic drug must be engaged in “bona fide marketing” to be considered as marketed, which affects when a branded drug exits the negotiation program. The company argued that these rules exceeded the agency’s statutory authority and that the program deprived it of protected property interests without due process.The United States District Court for the District of Columbia reviewed the case. It found that the statutory bar on judicial review did not prevent the company’s challenges to generally applicable agency guidance. On the merits, the district court upheld the agency’s definition of a qualifying single source drug, ruled that the challenge to the “bona fide marketing” standard was not yet ripe, and rejected the due process claim due to lack of a protected property interest. The company appealed.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The appellate court held that the statutory review bar precludes review only of drug-specific determinations, not generally applicable legal standards. On the merits, it concluded that the statute permits the agency to treat drugs with the same active ingredient and manufacturer as one statutory drug. The court found that the due process challenge failed because the company lacked a protected property interest. However, it determined that the challenge to the “bona fide marketing” requirement was ripe and remanded that issue to the district court for further proceedings. The court thus affirmed in part, reversed in part, and remanded. View "Teva Pharmaceuticals USA, Inc. v. Kennedy" on Justia Law

A technology company, along with its U.S. subsidiary, was designated by the Secretary of Defense as a “Chinese military company” under Section 1260H of the National Defense Authorization Act. This listing, published annually in the Federal Register, leads to significant legal consequences, including prohibitions on entering into certain federal contracts and receiving federal funds or support. The designation also carries reputational harm, as it publicly identifies the company as having ties to the Chinese military. The company develops and sells LiDAR products primarily used in advanced driver-assistance and autonomous vehicle systems.After being listed in January 2024, the company sued the Department of Defense in the United States District Court for the District of Columbia, challenging both the original and an October 2024 redesignation under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The company argued that it was not provided notice of the unclassified evidence relied upon or a meaningful chance to respond before the designation was finalized. The district court granted summary judgment to the government, upholding the designation and concluding that any due process violation was harmless because the company did not show prejudice.On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the company had a protected liberty interest under the “stigma-plus” doctrine, as the designation combined reputational harm with formal exclusion from government contracting opportunities. The Court ruled that the Constitution required the Secretary to provide notice of the unclassified evidence and a meaningful pre-deprivation opportunity to respond. The Secretary’s failure to do so was not harmless error. The appellate court reversed the district court’s judgment and remanded with instructions to remand to the Secretary for further proceedings, but did not vacate the designation pending remedial process. View "Hesai Technology Co., Ltd v. DOD" on Justia Law

In June 2017, the defendant drove his truck into an alley and ran over two individuals sleeping under a blanket, resulting in one fatality and one serious injury. After being told by a witness that he had run over people, he denied it and drove away from the scene. Law enforcement, acting on witness information, located the defendant at his home, where he exhibited signs of alcohol use. Subsequently, the defendant was charged with leaving the scene of an accident resulting in death and with leaving the scene of an accident resulting in serious bodily injury. The prosecution later added habitual criminal counts based on prior felony convictions.At trial in the district court, the jury was instructed on the elements of the leaving-the-scene offenses without any requirement that the defendant acted with a culpable mental state, such as “knowingly.” The jury convicted the defendant on both charges. The judge, not a jury, adjudicated the defendant as a habitual offender and imposed a sixty-year sentence. The defendant appealed, arguing the trial court erred by not requiring proof of a mental state for the leaving-the-scene offenses and challenging the constitutionality of the habitual offender statute for permitting a judge, rather than a jury, to make factual findings that increased his sentence.The Colorado Court of Appeals affirmed both the convictions and the habitual offender adjudication, finding itself bound by existing precedent and concluding any error was harmless beyond a reasonable doubt. On review, the Supreme Court of Colorado held that its prior decision in People v. Manzo remains controlling, so the trial court did not err in omitting a culpable mental state from the jury instructions for the leaving-the-scene convictions. The court further held that the habitual offender statute was not unconstitutional and that any error in the judge’s factual findings, rather than a jury’s, was harmless beyond a reasonable doubt. The court affirmed the lower court’s judgment. View "Brown v. People" on Justia Law

A priest formerly affiliated with the Russian Orthodox Church Outside of Russia (ROCOR) brought suit against various church leaders and entities, alleging defamation. He claimed that leaders within ROCOR falsely accused him of forging letters from church officials that purportedly announced his election as a bishop. The priest maintained that he had been chosen for elevation, and that the accusations of forgery, which circulated within the church and were subsequently posted online, damaged his reputation and led to his suspension and eventual removal from clerical office.The United States District Court for the Southern District of New York, upon reassignment to a new judge, granted summary judgment to the defendants. The court found that the plaintiff failed to present sufficient evidence under New York defamation law linking the defendants to the public dissemination of the allegedly defamatory statements. Additionally, the court held in the alternative that the lawsuit was barred by the First Amendment’s church autonomy doctrine, as adjudicating the claims would require the court to intrude upon religious questions regarding ROCOR’s selection, supervision, and discipline of clergy, as well as its internal governance protocols.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision, focusing on the constitutional ground. The Second Circuit held that the First Amendment’s church autonomy doctrine prevents civil courts from adjudicating claims that would interfere with a religious organization’s management of its ministers or require secular courts to resolve disputes over church protocols and internal governance. The court concluded that the plaintiff’s claims, whether based on internal or public statements, were barred because their resolution would necessitate unconstitutional entanglement in matters of church governance and doctrine. View "Belya v. Kapral" on Justia Law

The appellant was arrested in Mississippi, extradited to Georgia, and released on bond. He was charged with theft by conversion stemming from a dispute involving the sale of a tractor-trailer. While on bond, he filed a pretrial habeas corpus petition, arguing that he continued to be unconstitutionally restrained due to ongoing bond conditions and pending prosecution. He requested the court to order the State to justify the restraint and sought a prompt hearing on probable cause. He also objected to the assignment of his habeas case to the same judge presiding over his criminal case, repeatedly seeking that judge’s recusal.The Superior Court of Gwinnett County assigned his habeas petition to Judge Tracey Mason, who denied multiple motions for her own recusal, explaining that adverse rulings are not grounds for disqualification. When the habeas petition came for hearing, a different judge, Judge Kylene Armond, presided by designation. The appellant refused to participate in the hearing, insisting that a new judge should be assigned before he would proceed. Judge Armond noted the appellant offered no evidence and warned that the petition could be dismissed for failure to prosecute. The appellant maintained his refusal, and Judge Armond dismissed the petition due to his failure to present evidence or pursue the claim.On appeal, the Supreme Court of Georgia considered only the dismissal order. The Court held that because the appellant failed to challenge the dismissal on the ground that he presented no evidence, that ground was presumed correct and binding. The Court further found that the recusal issue was irrelevant, since the judge whose recusal was sought did not dismiss the petition. The judgment of dismissal was affirmed. View "TWUM-BAAH v. THE STATE" on Justia Law

Rodney Greene was convicted for the felony murder of Tyjerus White following a shooting incident. On the night of the incident, White drove with three companions to visit a friend. While they were parked outside, Greene approached the car, acted aggressively, and initiated a confrontation with White and his companions. Witnesses testified that Greene appeared intoxicated and escalated the situation by threatening White with a lighter and later brandishing a handgun. After a heated argument, White attempted to leave but was confronted again by Greene, resulting in gunfire. White was fatally wounded and later found in his crashed vehicle. A .22 caliber bullet was recovered from White’s body, and shell casings at the scene matched a .22 caliber firearm, which was never found. Greene was arrested weeks later and admitted to the shooting.The Superior Court of Sumter County conducted a jury trial, which found Greene guilty of felony murder and aggravated assault. Greene was sentenced to life imprisonment with the possibility of parole. He filed a motion for a new trial, which the trial court denied after a hearing. Greene then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient to disprove his claim of self-defense and raising two claims of ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case and held that the evidence was constitutionally sufficient for a rational jury to find Greene guilty beyond a reasonable doubt and to reject his justification defense. The Court also concluded that Greene’s trial counsel was not constitutionally ineffective either for failing to seek a mistrial due to alleged juror misconduct or for not calling a GBI agent whose testimony would have been inadmissible hearsay. The Supreme Court of Georgia affirmed Greene’s conviction. View "GREENE v. THE STATE" on Justia Law